Elementary Work vs. Servicing Under the Canadian Aviation Regulations

Under the Canadian Aviation Regulations, aircraft work is divided into three distinct regulatory tiers with fundamentally different legal obligations:

1. Servicing (CAR 101.01(1)): Cleaning, lubricating, and replenishing fluids without disassembly. Servicing is explicitly excluded from the definition of maintenance, requires no maintenance release, and does not require an AME licence.

2. Elementary work (Standard 625, Appendix A; CAR 101.01(1)): A specific, exhaustive list of 29 maintenance tasks that are exempt from the requirement for a maintenance release under CAR 571.10(3) and CAR 605.85(4). It does not require an AME licence, but requires owner/operator authorization under CAR 571.10(3) and must be entered in the aircraft journey log with a signature or employee identifier (CAR 571.03; CAR 605.93; CAR 605.94).

3. Maintenance (CAR 101.01(1)): Overhaul, repair, required inspection, modification, or component removal/installation. Standard maintenance requires a maintenance release signed by a qualified, rated AME or authorized individual under CAR 571.11 before the aircraft may fly (CAR 605.85).

CAR 101.01(1) defines "servicing" with precision: "servicing, in respect of an aeronautical product, means cleaning, lubricating and the replenishment of fluids not requiring the disassembly of the product."

Crucially, CAR 101.01(1) explicitly excludes servicing from the statutory definition of "maintenance." Because servicing is not maintenance, the maintenance release requirement of CAR 571.10 and CAR 605.85 does not apply to it. Any individual competent in basic ground handling procedures — such as fueling personnel or pilots — may perform servicing without an AME licence, AMO authorization, or formal MCM task listing.

CAR 101.01(1) defines "elementary work" as "those tasks that are listed as elementary work in the Aircraft Equipment and Maintenance Standards." Standard 625, Appendix A defines it as "a form of maintenance that is not subject to a maintenance release."

Unlike servicing, elementary work is legally a form of maintenance that involves physical disturbance, adjustment, or replacement of parts (such as changing spark plugs, replacing tires, or swapping avionics). Standard 625, Appendix A sets out an exhaustive 29-item list. If a task is not on that list, it cannot be treated as elementary work regardless of how simple it appears.

While elementary work "need not be performed by a holder of an AME licence, or by persons working under an AMO certificate" (Standard 625 Appendix A), it is subject to strict performer authorization rules under CAR 571.10(3) and owner control.

CAR 101.01(1) defines "maintenance" as "the overhaul, repair, required inspection or modification of an aeronautical product, or the removal of a component from or its installation on an aeronautical product," excluding elementary work and servicing.

Any task falling within this definition requires compliance with CAR Part V (Airworthiness) standards and cannot be completed without a formal aircraft maintenance release under CAR 571.10, entered in the technical record and signed by a qualified AME or AMO ACA holder under CAR 571.11.

The core legal distinction among the three tiers centers on the maintenance release required under CAR 605.85(1) before flight:

• Servicing: Excluded from the definition of "maintenance" in CAR 101.01(1). No maintenance release is required or issued.

• Elementary work: Carved out from the maintenance release requirement under CAR 571.10(3) and CAR 605.85(4). No maintenance release is required when performed by an authorized person under CAR 571.10(3).

• Maintenance: Full maintenance release required under CAR 571.10(1) and CAR 605.85(1). Aircraft takeoff is prohibited until a rated AME or authorized person under CAR 571.11 certifies that the work conforms to applicable airworthiness standards.

Being exempt from a maintenance release is not the same as being exempt from the technical record. The three tiers diverge here too:

• Elementary work: must be recorded. CAR 605.94 requires every task designated as elementary work to be entered in the aircraft journey log. Standard 571.03(1) sets the particulars — product identification (unless already recorded), a brief description of the work, and a reference to any non-standard method used — and CAR 605.93 requires the performer to add their name plus signature or employee identifier (or user code, for an electronic record). Standard 571.03's information note states this entry "is the responsibility of the person performing the work" and is "distinct from the maintenance release."

• Maintenance: same technical-record entry, plus the signed maintenance release statement under CAR 571.10 identifying the AME or AMO authorization.

• Servicing: not maintenance, so the CAR 571.03 / 605.93 maintenance-entry rules do not apply. Operators may still log fluid top-ups for trend monitoring, but that is a practice, not a regulatory maintenance signature.

• Servicing: any person competent in the servicing procedure — line crew, fuellers, pilots. No licence or MCM authorization is required by the CARs.

• Elementary work: only the persons listed in CAR 571.10(3) — a private pilot on a glider, balloon or unpressurized small piston aircraft; a person trained and authorized under an approved FTU or air operator MCM (with the task individually listed in that manual, per Standard 625, Appendix A); or a person trained under a Part VI, Subpart 4 private-operator operations manual — with the owner responsible for controlling authorizations. Our guide on what elementary work is covers these categories in full.

• Maintenance: the holder of an appropriately rated AME licence (CAR 571.11(1)), a person signing under an AMO's maintenance policy manual (CAR 571.11(3)), or a person meeting the transport-category / turbine-helicopter training requirement (CAR 571.11(4)), plus the narrow exceptions in CAR 571.11(2).

The tier a task falls into always depends on the exact wording and conditions of CAR 101.01 and Standard 625, Appendix A for the specific aircraft — the examples below illustrate the boundary but do not classify any real task on their own.

Engine oil: topping up the reservoir without disassembly fits the CAR 101.01(1) definition of servicing. Draining and replenishing engine oil, and cleaning or changing the oil filter, on a small privately operated aircraft are listed elementary work (Standard 625, Appendix A, items 8 and 7) and need a journey-log entry. Replacing an oil cooler is not servicing and is not a listed Appendix A task, so it is not elementary work; as the removal and installation of a component it falls within the CAR 101.01 definition of maintenance, and a maintenance release applies.

Tires: checking and adjusting tire pressure is elementary work (Appendix A, item 28, except on CAR 705 aircraft). Removing and replacing tires or wheels on a small privately operated aircraft without separating hydraulic lines is elementary work (item 2). The same wheel change on a transport category aeroplane is not within item 2, so it is not elementary work; as component removal and installation it is maintenance under CAR 101.01, and a release applies.

Spark plugs: cleaning and replacing spark plugs on a small privately operated aircraft is elementary work (Appendix A, item 5). On any other category of aircraft the task is not within item 5, so it is not elementary work; as component removal and installation it is maintenance under CAR 101.01, and a release applies.

Avionics: removing and replacing a rack-mounted unit designed for rapid change where the work needs no testing beyond an operational check is elementary work (Appendix A, item 18). Installing new wiring or modifying an instrument panel is neither servicing nor a listed Appendix A task, so it is not elementary work; it is a modification within the CAR 101.01 definition of maintenance, and a release signed by an AME with the appropriate rating applies.