What Is Elementary Work Under the Canadian Aviation Regulations?

Elementary work is a specific, named category of maintenance defined by an exhaustive, itemized list in Standard 625, Appendix A — not a general term for maintenance that happens to be simple or minor. A task designated as elementary work needs no maintenance release (CAR 571.10(3); CAR 605.85(4)) and does not require an AME licence or AMO certificate to perform (Standard 625, Appendix A). But that does not mean anyone may perform it, or that no requirements apply at all: CAR 571.10(3) limits who may perform it to specific categories of person tied to how the aircraft is operated, and the owner is responsible for controlling those authorizations.

Standard 625, Appendix A states directly: "Elementary work is a form of maintenance that is not subject to a maintenance release." It is a defined term tied to a specific list, not a description of task difficulty. The Standard also requires that "the performance of all tasks designated as elementary work shall be entered in the technical record for the aeronautical product" under CAR 571.03 and Subpart 605, Division IV — elementary work is release-exempt, not record-exempt.

Standard 625, Appendix A is explicit about its own scope: "The following list is exhaustive; if a task is not listed, it is not elementary work." The list contains 29 specific items, and each item carries its own precise wording and conditions — some apply only "on small privately operated aircraft" (items 1–10, covering things like fabric patches, tire/ski replacement, spark-plug cleaning, and oil changes); others apply more broadly but are conditioned on the component being "designed for rapid removal and replacement," on the work not requiring "testing other than an operational check," or on the aircraft not being a specific category (item 20, for example, applies "on other than transport category aircraft"). The list is not a set of examples — a task has to match a specific item's exact wording to qualify.

CAR 571.10(3) states that "no maintenance release is required in respect of any task designated as elementary work in the Aircraft Equipment and Maintenance Standards" when performed by one of the categories of person described below. CAR 605.85(4) states the same exemption from the take-off-certification side: "No maintenance release is required in respect of tasks identified as elementary work in the Aircraft Equipment and Maintenance Standards." See our Who Can Sign a Maintenance Release guide for how this exemption fits into the broader maintenance-release framework.

Standard 625, Appendix A states that 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 mean elementary work is 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 (see below). No AME licence being required and no restriction on who may perform it are different things; only the first is true.

CAR 571.10(3) ties the maintenance-release exemption to the person performing the task, and names exactly three categories: (a) the pilot of the aircraft, for a glider, balloon, or unpressurized small piston aircraft not operated under Part IV or VII; (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 Part VII respectively, for aircraft operated under Part IV or VII; or (c) a person trained in accordance with a private operator's operations manual maintenance-control-system provisions, for aircraft operated under Subpart 4 of Part VI. A person outside these three categories performing what would otherwise be elementary work is not covered by this specific exemption.

For Part IV/VII aircraft, CAR 571.10(3)(b) requires the performer to be both trained and authorized under the operator's approved MCM — training alone is not stated as sufficient. Standard 625, Appendix A adds a further, related condition specifically for aircraft operated under Subpart 406 and Part VII: the applicable tasks are 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," referencing CAR 571.10(3)(b) directly. For Part VI, Subpart 4 aircraft, CAR 571.10(3)(c) requires training under the private operator's own operations manual — the Standard does not state an equivalent individual-task-listing requirement for this category in the text quoted above.

Outside the Part IV/VII/Subpart 4 cases above, Standard 625, Appendix A states a general rule: "The owner is responsible for controlling authorizations to persons who may perform elementary work." Elementary work is release-exempt and licence-exempt, but it is not authorization-exempt — someone still has to be responsible for deciding who is allowed to do it, and CAR 571.10(3) still has to be satisfied for the applicable category.

Whether a task is elementary work depends on matching Appendix A's exact item wording — not on how simple or low-risk the work seems. The Standard's own information notes make this explicit for item 29 (certain repetitive visual inspections and operational checks): the same task "is elementary work when performed out of phase" with the aircraft's scheduled check cycle, "but require[s] a maintenance release when done as part of a scheduled maintenance check." Identical work, different classification, depending on timing — not on the task's inherent complexity. Similarly, items 1 through 10 apply only "on small privately operated aircraft"; the same task performed on a different category of aircraft is not covered by those items. A task that sounds minor but is not listed — or is listed but does not meet its item's specific conditions — still requires a maintenance release like any other maintenance.

Elementary work sits outside, and prior to, the entire maintenance-release-authority framework: the AME-licence, AMO/ACA, and type-training conditions covered in our Who Can Sign a Maintenance Release and CAR 571.11 Type-Training Requirements guides only engage once a maintenance release is actually required. Confirming a task genuinely matches an Appendix A item — and that whoever performs it fits one of CAR 571.10(3)'s three categories — comes first; if either check fails, the task is not elementary work and the ordinary maintenance-release-authority conditions apply in full.