Policy Letter 144
Review of company manuals
During the review of manuals or documents, inspectors are to refrain from making significant corrections on behalf of those submitting the manuals or documents for approval.
Subsections 702.81(4), 703.104(4), 704.120(4) and 705.134(4) of the Canadian Aviation Regulations (CARs).
Following the CARs implementation in 1996, Transport Canada assisted operators in a comprehensive review of their documents. However, Commercial and Business Aviation Inspectors are still spending a significant amount of time correcting manuals and documents submitted for approval, in effect providing a consultation service to the Industry. That adjustment period is now behind us and operators should be expected to have manuals and documents that meet the CARs.
The responsibility for manual or document development must reside with industry. It is not the mandate of the Minister to write manuals or documents for the Industry, but rather to review and approve them on behalf of the Minister.
Effective immediately, Commercial and Business Aviation Inspectors are to stop the review/approval process upon finding significant errors in a submitted manual or document (five significant items uncovered in a preliminary assessment) and return the manual or document to the originator for further action.
Significant errors shall be identified to the originator of the manual or document by quoting the Regulatory requirement and deficiency. i.e."Section XX of the submitted manual does not meet the requirement of paragraph c) of the Standard 725.135 in that it does not contain a list of effective pages".
If the originator then re-submits the manual or document and three significant errors are found, the manual or document is to be returned again to the originator for further action.
At no time are inspectors to rewrite or add to a submitted manual or document.
The Regional Manager Commercial and Business Aviation at his discretion, may continue the review/approval process after significant errors have been found.
The Industry should be encouraged to make use of available checklists, Commercial and Business Aviation Advisory Circulars or other reference materials, and should also be encouraged to seek professional assistance in preparing manuals or documents for the Minister's approval.
Note: Significant errors to manuals or documents are considered to be errors with respect to compliance with the Canadian Aviation Regulations and Standards. Significant errors are not spelling or formatting. However, poor organization or presentation of material is a significant error.
This Policy Letter will remain in effect until revoked.
Commercial &Business Aviation
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