Aircraft Technical Records and Journey Log Requirements in Canada

Under CAR 605.92, every aircraft owner must keep a journey log, a separate technical record for the airframe, each installed engine and each variable-pitch propeller, and an empty weight and balance report. Every person who performs maintenance or elementary work must ensure a technical-record entry is made for the task (CAR 571.03), and every person who makes any technical-record entry must record their name and signature or employee identifier and date the entry (CAR 605.93).

A technical-record entry is not the same as a maintenance release. The entry documents what was done, when and by whom; the maintenance release (CAR 571.10) is the separate airworthiness certification that lets the aircraft fly (CAR 605.85). One entry can also serve as the release, but only if the CAR 571.10 and 605.93 requirements for a release are all met.

CAR 605.92(1) requires every owner of an aircraft to keep: "(a) a journey log; (b) subject to subsections (2) and (3), a separate technical record for the airframe, each installed engine and each variable-pitch propeller; and (c) except where otherwise provided under the terms of a fleet empty weight and balance program referred to in subsection 706.06(3), an empty weight and balance report that meets the applicable standards set out in Standard 571 — Maintenance."

CAR 605.92(2) allows the airframe/engine/propeller records to instead be kept as separate records for each installed component, and CAR 605.96(3) provides that a component's technical record becomes part of the record for the higher assembly once the component is installed on it.

CAR 605.92(3) contains a narrow exception: for a balloon or glider, or an aircraft operated under a special certificate of airworthiness in the owner-maintenance or amateur-built classification, all of the airframe/engine/propeller and weight-and-balance entries may be kept in the journey log. This guide otherwise assumes a type-certificated aircraft with the full set of separate records.

The journey log and the airframe/engine/propeller records serve different purposes and are governed by different lists. CAR 605.94(1) sends journey-log particulars to Schedule I of Subpart 605, Division IV; CAR 605.96(1) sends the airframe/engine/propeller/component particulars to Schedule II. Each Schedule sets, for every item, the particulars, the time of entry, and the person responsible.

Schedule I (journey log) covers, among other items: the aircraft identification and marks (item 1); empty weight and centre of gravity and any change (item 2); air time of each flight and cumulative totals (item 4); the maintenance-schedule description and next due point (item 5); abnormal occurrences (item 6); conditional maintenance release particulars (item 7); test-flight results (item 8); defects that become apparent in flight (item 9); defects not rectified before the next flight (item 10); and "particulars of any maintenance action or elementary work performed in respect of items 2, 6, 9, and 10" (item 11).

Schedule II (airframe, engine, propeller or component record) covers the product identification and configuration (item 1); the scheduling provisions of applicable airworthiness directives (item 2); abnormal occurrences recorded in the journey log under Schedule I item 6 (item 3); and "the particulars of any maintenance performed, including the particulars of any maintenance performed in order to comply with the requirements of an airworthiness directive" (item 4), together with total air time and cycles at that point (item 5).

The practical split is set by Standard 625.93(4): the only defects that must be entered in the journey log are those that arise during flight operations (Schedule I item 9) and those not rectified before the next flight (item 10). "All other defects may be entered directly into the applicable airframe, engine, propeller or component record," and where a defect and its rectification were first entered in the journey log they must be transcribed into the applicable record within 30 days. Routine maintenance particulars belong in the Schedule II record, not the journey log.

Elementary work is treated differently. Transport Canada's Standard 571.03 states in an information note that "section 605.94 of the CARs requires that all tasks designated as elementary work be recorded in the journey log," and Standard 625, Appendix A requires every elementary-work task to be entered in the technical record. Read literally, Schedule I item 11 only requires a journey-log entry for maintenance or elementary work performed in respect of items 2, 6, 9 and 10 — a narrower trigger. The literal Schedule wording is the regulation; the broader "all elementary work goes in the journey log" position is Transport Canada's standard-level interpretation. See our guide to what elementary work is for how the record requirement fits the elementary-work rules.

CAR 571.03 itself is short: a person who performs maintenance or elementary work must ensure "the details required by Standard 571 — Maintenance are entered in the technical record" for the task, and that the record is accurate as to outstanding work, "in particular, the need to secure any fastening device that was disturbed to facilitate the work."

Standard 571.03(1) sets out the details. The entry must record: (a) product identification — aircraft registration marking, nomenclature, type/model number, manufacturer, part number and serial number — unless the entry is being made in a technical record that already contains this information; (b) a brief description of the work performed; (c) where a standard other than the manufacturer's recommended practice is used, a reference to the standard used; (d) the date the maintenance was performed and the identification of the employee who accomplished the task; (e) where the repair includes making and installing repair parts under CAR 571.06(4), a statement to that effect; (f) where disassembly was required, a general description of any defect found before re-assembly; (g) where a task is partially completed, a general description of the outstanding work, including the specific location of any parts or systems that have been disturbed; and (h) where a part was accepted under Appendix H of Standard 571, a statement that it was inspected and tested and a maintenance release issued to that effect.

Standard 571.03(1) adds two information notes: the non-standard-method reference in (c) is unnecessary when the manufacturer's instructions provide no optional method; and if the entry itself constitutes the maintenance release, the date must be shown and all of CAR 571.10 and CAR 605.93 must be complied with.

CAR 605.93(1) requires every person who makes an entry in a technical record to "(a) make the entry accurately, legibly and in a permanent manner; (b) enter the person's name and signature or employee identifier or, where the record is kept as electronic data, enter the person's user code or an equivalent security designation; and (c) date the entry."

CAR 605.93(4) requires that when a new volume of an existing record is brought into use, the entries needed to maintain "an unbroken chronological record" are made linking it to the preceding volume.

CAR 605.93(5) sets the correction method: strike out the incorrect entry "in such a manner that the underlying information remains legible," and insert the correct entry together with the date of the alteration, the reason for it if needed to clarify why it was made, and the person's name and signature or employee identifier (or user code). Entries are not erased or overwritten.

CAR 605.93(2) permits technical records to be kept as electronic data, but requires the owner to ensure the electronic data system "complies with section 103.04 and the Aircraft Equipment and Maintenance Standards." CAR 103.04 is the CARs' general provision on electronic records and signatures.

CAR 605.93(6) requires that a correction made to an electronic record be done "in a manner that does not render the original data inaccessible." Standard 625.93 adds that electronic records must be protected from damage or loss to the same extent as paper records, that corrections must not delete any original entry, and — in its information notes — that electronic maintenance-record systems should have a regularly updated backup and safeguards against both accidental alteration by authorized personnel and intentional alteration by unauthorized individuals.

These are two separate acts. The technical-record entry under CAR 571.03 and CAR 605.93 documents the work: what was done, on what product, when, and by whom. The maintenance release under CAR 571.10 is the additional statement — "The described maintenance has been performed in accordance with the applicable airworthiness requirements" — that CAR 605.85(1) requires before an aircraft that has undergone maintenance may take off.

Standard 571.03's information note is explicit: "Compliance with section 571.03 of the CARs is the responsibility of the person performing the work. This regulation is applicable to the making of an entry into a technical record, which is distinct from the maintenance release addressed by section 571.10 of the CARs."

The same entry can serve as the maintenance release, but only where the date is shown and all of CAR 571.10 and CAR 605.93 are satisfied (Standard 571.03(1), information note (ii)). Elementary work performed by an authorized person under CAR 571.10(3) needs the technical-record entry but no maintenance release. Who may sign a release, and on what conditions, is covered in our guide to who can sign a maintenance release.

Elementary work is exempt from a maintenance release but not from the record. Standard 625, Appendix A states that "the performance of all tasks designated as elementary work shall be entered in the technical record for the aeronautical product, as required by section 571.03 of the CARs and in accordance with Subpart 605, Division IV." The particulars are the Standard 571.03(1) list, and CAR 605.93 supplies the name-and-signature requirement.

Servicing is different. CAR 101.01(1) defines servicing as "cleaning, lubricating and the replenishment of fluids not requiring the disassembly of the product," and excludes servicing from the definition of "maintenance." Because servicing is neither maintenance nor elementary work, no provision of CAR 571.03, CAR 605.94, CAR 605.96 or Schedules I and II requires a maintenance-record entry for it — the "no entry required" conclusion follows from servicing's exclusion from those provisions rather than from an express statement. Operators commonly still log fluid additions for consumption monitoring, but that is a practice, not a regulatory maintenance signature. Our guide comparing elementary work and servicing sets out the wider distinction.

The two responsibilities sit with different people. Under CAR 571.03 and the Standard 571.03 information note, making the entry is "the responsibility of the person performing the work." Schedule I column III names the responsible person item by item — for example the owner for the aircraft-identification and maintenance-schedule items, the pilot-in-command (or an operator-designated person) for the air-time entry, and "the person who performed the maintenance action or elementary work and, where applicable, the person signing the maintenance release" for Schedule I item 11.

Keeping the records is the owner's responsibility. CAR 605.92(1) puts the obligation to keep the records on the owner; CAR 605.93(2) makes the owner responsible for ensuring any electronic system complies; and CAR 605.93(3) requires the owner to "ensure that all of the necessary measures are taken to protect the technical records for the aircraft from damage and loss."

This aircraft journey log and technical record is a record of the aircraft — it is not the same document as an AME candidate's personal experience logbook, which records the individual's work history for a licence application under Standard 566 and is covered in our AME logbook guide.

CAR 605.95(1) prohibits a take-off unless the journey log is on board the aircraft. CAR 605.95(2) provides two exceptions: where it is not planned that the aircraft will land and shut down anywhere other than the point of departure; or where the aircraft is a balloon and the journey log is immediately available to the pilot-in-command before commencing and on completing the flight. The airframe, engine and propeller records are not required to be carried on board.

Journey log: CAR 605.94(3) requires the owner to retain every entry in a journey log "for a period of not less than one year."

Other technical records: CAR 605.96(4) requires them to be retained "for the applicable period set out in the Aircraft Equipment and Maintenance Standards." Standard 625.96(1) sets that period — the owner "shall maintain and retain technical records, other than the Journey Log, until such time as the aircraft is no longer registered" — and Standard 625.96(2) adds that records of repetitive inspections need only be kept until the inspection activity is next repeated.

Transcription: where particulars of maintenance are transferred out of the journey log into another technical record, CAR 605.96(2) requires the responsible person either to transcribe the particulars together with "the name and identification number of the person who made the original entry," or, where the journey log has detachable copies, to attach the copy of the page to the applicable record. Standard 625.93(4) allows 30 days for this transcription where a defect and its rectification were first recorded in the journey log.

Transfer: CAR 605.97 requires every owner who transfers title to an aircraft, airframe, engine, propeller or appliance to "at the time of transfer, also deliver to that person all of the technical records that relate to that aeronautical product."