What Is Elementary Work Under the Canadian Aviation Regulations?

Elementary work is a specific, legally defined form of maintenance set out in an exhaustive, itemized list in Standard 625, Appendix A — not a generic label for maintenance that happens to be simple, routine, or minor.

A task designated as elementary work does not require an aircraft maintenance release (CAR 571.10(3); CAR 605.85(4)) and does not require an AME licence or an AMO certificate to perform (Standard 625, Appendix A). However, elementary work is neither unregulated nor open to anyone: CAR 571.10(3) restricts who may perform it to specific categories of persons tied to how the aircraft is operated, the owner is responsible for controlling authorizations, and every task performed must still be entered in the technical record (journey log) with a signature or employee identifier under CAR 571.03 and CAR 605.93/605.94.

Under CAR 101.01(1), "elementary work means those tasks that are listed as elementary work in the Aircraft Equipment and Maintenance Standards." Standard 625, Appendix A elaborates: "Elementary work is a form of maintenance that is not subject to a maintenance release. Hence, it need not be performed by a holder of an AME licence, or by persons working under an AMO certificate."

Crucially, elementary work remains a form of maintenance in its physical nature, but is carved out from the standard maintenance release requirement. Standard 625, Appendix A explicitly mandates: "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 – Technical Records." Elementary work is release-exempt, but never record-exempt.

Standard 625, Appendix A is explicit about its legal boundary: "The following list is exhaustive; if a task is not listed, it is not elementary work." The 29 items each carry their own precise wording and conditions; they can be grouped for reference as follows.

• Restricted to small privately operated aircraft (Items 1–10): fabric patches not more than 15 cm (6 in) in any direction, not requiring rib stitching or removal of control surfaces or structural parts (1); removal and replacement of tires, wheels, landing skids or skid shoes not requiring separation of any hydraulic lines (2); removal and replacement of skis on fixed landing gear without separating hydraulic lines (3); repair of non-structural fairings, cover plates and cowlings (4); cleaning and replacement of spark plugs (5); checking of cylinder compression (6); cleaning or changing of fuel, oil and air filters (7); draining and replenishing engine oil (8); checking the electrolyte level and specific gravity of lead-acid batteries (9); adjustment of generator or alternator drive belt tension (10).

• Rapid-change, cabin and component tasks (Items 11–26): cleaning of balloon burner nozzles (11); removal and replacement of balloon baskets, burners and gas tanks designed for rapid change (12); removal and replacement of glider wings and tail surfaces designed for quick assembly (13); repair of upholstery, trim and cabin furnishings (14); removal and replacement of role equipment designed for rapid removal and replacement (15); removal and replacement of passenger seat belts and harnesses (16); removal and replacement of fuses, light bulbs and reflectors (17); removal and replacement of rack-mounted or otherwise rapid-removal avionics components where the work requires no testing other than an operational check (18); removal and replacement of aircraft batteries (19); removal and replacement of co-pilot control levers, wheels, pedals and pedal guard plates designed for rapid removal and replacement, on other than transport category aircraft (20); opening and closing of non-structural access panels (21); removal and replacement of cabin doors on unpressurized aircraft where the door is designed for rapid removal and replacement (22); removal, replacement and repositioning of non-structural partitions in the passenger cabin (23); inspection and continuity checking of self-sealing chip detectors (24); removal and replacement of induction system anti-icing baffles, scoops and deflectors designed for rapid removal and replacement (25); removal, cleaning, replacement and adjustment of external components of chemical dispersal systems designed for rapid removal and replacement (26).

• System deactivation (Item 27): deactivating or securing inoperative systems in accordance with CAR 605.09 or 605.10, including installing devices specifically intended for system deactivation, where the work involves no disassembly, no installation of parts, and no testing other than operational checks.

• Tire and float pressure (Item 28): checking and adjusting air pressure in helicopter floats and aircraft tires, except on aircraft operated under CAR 705.

• Repetitive out-of-phase checks (Item 29): repetitive visual inspections or operational checks (including inspections and tests required by airworthiness directives) not involving disassembly or the use of visual aids, performed out of phase with the aircraft's scheduled check cycle at intervals of less than 100 hours air time, provided the tasks are also included in the most frequent scheduled maintenance check.

One of the Standard's own information notes narrows item 27 further: an "operational check" only determines whether a unit is working — it does not measure performance against a predetermined standard, and where the test procedure requires such measurement the replacement is not elementary work.

Under CAR 571.10(1), maintenance performed on an aeronautical product requires a maintenance release certifying that the work conformed to applicable airworthiness requirements before flight (CAR 605.85(1)).

CAR 571.10(3) provides the statutory carve-out: "No maintenance release is required in respect of any task designated as elementary work in the Aircraft Equipment and Maintenance Standards," provided the task is performed by one of the authorized categories of persons. CAR 605.85(4) mirrors this rule for take-off authorization: "No maintenance release is required in respect of tasks identified as elementary work in the Aircraft Equipment and Maintenance Standards."

Standard 625, Appendix A says elementary work "need not be performed by a holder of an AME licence, or by persons working under an AMO certificate." That removes the AME-licence and AMO-certificate requirements specifically — it does not make elementary work unregulated or open to anyone. CAR 571.10(3) independently limits who may perform it, and the Standard puts the owner in charge of controlling authorization. "No AME licence required" and "no restriction on who may perform it" are different statements; only the first is true.

Exemption from a maintenance release does not exempt the performer from logging the work. Standard 625, Appendix A states directly that "the performance of all tasks designated as elementary work shall be entered in the technical record for the aeronautical product," and CAR 571.03 makes the person who performs the work responsible for ensuring the entry is made.

The particulars that must be recorded are set out in Standard 571.03(1): (a) product identification — registration marking, nomenclature, type/model, manufacturer, part number and serial number — unless the technical record already contains it; (b) a brief description of the work performed; and (c) where a standard other than the manufacturer's recommended practice is used, a reference to that standard. Standard 571.03's own information note confirms that CAR 605.94 is what requires every task designated as elementary work to be recorded in the aircraft journey log specifically.

Under CAR 605.93, every person who makes a technical-record entry must add their name, and — for an entry in respect of maintenance or elementary work — their signature or employee identifier, or their user code where the record is kept as electronic data (the wording quoted in Standard 625, Appendix A).

Standard 571.03's information note is explicit that this is separate from any maintenance release: "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."

CAR 571.10(3) conditions the maintenance-release exemption on who performs the work, recognizing exactly three categories of performers:

1. Private small aircraft pilot (CAR 571.10(3)(a)): The pilot of the aircraft, in the case of a glider, balloon, or unpressurized small piston aircraft not operated under Part IV (Flight Training) or Part VII (Commercial Air Services).

2. Flight training unit or commercial air operator personnel (CAR 571.10(3)(b)): A person trained and authorized in accordance with the flight training unit's or air operator's maintenance control manual (MCM), "approved under Subpart 6 of Part IV or of Part VII, respectively" — that is, Subpart 406 for a flight training unit and Part VII for an air operator.

3. Private operator personnel under Part VI Subpart 4 (CAR 571.10(3)(c)): A person trained in accordance with the maintenance control system provisions of a private operator's operations manual.

If an individual outside these three categories performs an Appendix A task, the statutory exemption under CAR 571.10(3) does not apply, and a standard maintenance release by a qualified AME is required.

For commercial air operators (Part VII) and flight training units (Part IV, Subpart 6 / Subpart 406), training alone is not sufficient. CAR 571.10(3)(b) requires the performer to be both trained and authorized under the operator's approved MCM.

Furthermore, Standard 625, Appendix A establishes a strict prerequisite for commercial and FTU aircraft: the applicable tasks qualify as elementary work only "provided they are individually listed in the operator's maintenance control manual and or operational manual as applicable, along with a reference to the training to be undertaken by persons authorized to perform them." If a task from Appendix A is not individually listed in the operator's approved manual, it cannot be performed as elementary work on that operator's fleet.

For corporate and private operators under Part VI, Subpart 4 (CAR 604), CAR 571.10(3)(c) requires training in accordance with the operator's operations manual maintenance control system.

For private aircraft operating outside commercial MCM systems, Standard 625, Appendix A establishes a direct governance rule: "The owner is responsible for controlling authorizations to persons who may perform elementary work."

While elementary work removes the requirement for an AME licence or an AMO certificate, it does not permit unauthorized third parties to service an aircraft. The registered aircraft owner retains legal responsibility for ensuring anyone performing elementary work on their aircraft is properly authorized and competent to carry out the specific task.

A fundamental principle of Canadian aviation law is that task complexity does not determine regulatory classification. A task is elementary work only if it matches one of Standard 625, Appendix A's 29 items and satisfies all attached conditions.

For example, Standard 625, Appendix A Information Note (ii) highlights item 29 (repetitive visual inspections or operational checks): the identical inspection "is elementary work when performed out of phase" with the aircraft's scheduled maintenance check cycle, "but require[s] a maintenance release when done as part of a scheduled maintenance check." The work itself is identical, but the regulatory classification changes based on timing.

Similarly, items 1 through 10 apply strictly "on small privately operated aircraft." Performing spark plug replacement or tire replacement on a transport-category aeroplane or a commercial commuter aircraft does not fall under items 1–10, so it is not elementary work. What it is instead depends on the task: if it meets the CAR 101.01 definition of servicing it is servicing (see elementary work vs. servicing); otherwise, if it falls within the CAR 101.01 definition of maintenance (or another applicable regulatory category), the maintenance-release requirements of CAR 571.10 apply — no matter how minor the task appears.

Elementary work and maintenance release authority sit on opposite sides of a clear regulatory boundary. An AME licence (Standard 566), AMO Aircraft Certification Authority (Standard 573.05), and type-training certifications (CAR 571.11(4)) govern the legal authority to sign an aircraft maintenance release.

When work qualifies as elementary work under Standard 625 Appendix A and is performed by an authorized person under CAR 571.10(3), the entire maintenance release framework is bypassed. The performer signs the journey log entry (CAR 605.93), but does not issue a maintenance release under CAR 571.10. If the work is not elementary work and is not servicing, and it falls within the CAR 101.01 definition of maintenance, the standard maintenance-release requirements engage in full.