What you will know
Know the two duties that begin the moment a declaration is made for a model: the three documents that must reach every user, and the records the declarant must keep, produce on request, and hold for a defined period.
Both belong to the person who made the declaration under section 901.194 — not to the pilot, and not to whoever happens to sell the aircraft. CAR 901.200 CAR 901.201
Before this lesson
- You know whether a declaration has been made for your model, and by whom, because every duty on this page falls on that person. CAR 901.194
- You know the model is a small or medium remotely piloted aircraft system, the two classes Division XI is written for. CAR 901.200
- You know a declaration is a statement about a model and the Standard 922 requirements it names, because what has to be documented follows from those requirements. CAR 901.194
How it works
1. One duty faces the user, the other faces the Minister
Section 901.200 faces outward: the declarant makes three things available to each user of the model. Section 901.201 faces the regulator: the declarant keeps three categories of record and makes them available to the Minister on request. CAR 901.200 CAR 901.201
Read the audience of 901.200 closely, because it is where questions are built. The section does not say on request, on delivery or to a purchaser — it says each user, and a user is anyone operating that model, whether or not they bought it from the declarant. CAR 901.200
2. The three documents every user is owed
| The deliverable | What it is | |
|---|---|---|
| (a) | A maintenance program | Servicing and maintenance instructions, plus an inspection program that keeps the system ready CAR 901.200 |
| (b) | Any mandatory actions the declarant develops for the system | Its own paragraph — not a part of the maintenance program CAR 901.200 |
| (c) | An operating manual | Ten required contents, listed in step 4 CAR 901.200 |
Two things are deliberately not on that list. There is no acceptance letter — that is issued to the declarant, not handed to users — and there is no requirement that the documents be paper, filed, or acknowledged. CAR 901.200 CAR 901.196
3. The maintenance program has exactly two parts
Paragraph (a) names two components and no more: instructions for servicing and maintaining the system, and an inspection program whose purpose is to keep the system ready for operation. CAR 901.200
Mandatory actions are the trap here. They sit in paragraph (b), on the same footing as the maintenance program and the operating manual, so a declarant who folds them into the maintenance program has handed over two documents where the section requires three. CAR 901.200
4. The operating manual, item by item
Paragraph (c) lists ten contents. Grouped by what they answer: CAR 901.200
| The question | What the manual must state |
|---|---|
| What is this system? | A description of the system; and assembly, adjustment and modification instructions, plus instructions for integrating its elements CAR 901.200 |
| How is it loaded? | The ranges of weights and centres of gravity that are safe in normal and emergency conditions — and, where a combination is safe only within certain loading limits, those limits and the corresponding combinations CAR 901.200 |
| How is it flown, and how far? | For each flight phase and mode of operation: the conditions needed for a stable command and control link, and the minimum and maximum altitudes and velocities that are safe in normal and emergency conditions CAR 901.200 |
| What does the environment do to it? | The effects of foreseeable weather and other environmental conditions on performance CAR 901.200 |
| What can hurt people? | The characteristics that could severely injure crew members, and the design features and associated operations intended to protect persons not involved in the operation CAR 901.200 |
| What will it tell me? | The warning information given to the pilot when performance degrades in a way that could make the operation unsafe CAR 901.200 |
| What do I do? | Procedures for normal and emergency conditions CAR 901.200 |
Three of those rows are the ones candidates get wrong. The altitude and velocity entry is a range with both ends, "safely" applies in normal and emergency conditions, and the injury content runs in two directions — the crew inside the operation and the people outside it. CAR 901.200
5. What the declarant keeps, and who may ask
Subsection 901.201(1) requires the declarant to keep, and make available to the Minister on request: CAR 901.201
- a record of any mandatory actions developed for the system;
- the results of, and reports related to, the verifications undertaken to confirm that the model meets the Standard 922 requirements named in the declaration; and
- the results of any service difficulty investigations — but only if the declarant is required to run a service difficulty reporting system under section 901.197, which is the case for a model that has an acceptance letter. CAR 901.201 CAR 901.197
The second bullet is worth reading twice. The verification evidence is kept, not filed: the section requires it to be available to the Minister on request, and nothing in it requires the results to be sent with the declaration. CAR 901.201
One standard points back at this section instead of adding a document to the list. The C2 link standard requires C2 link performance information to be passed on to the operator — citing section 901.200 as the duty it belongs to — so that the operator can make informed decisions when designing operations and when making tactical decisions during an operation. Std 922.09
6. How long: the later of two dates
The retention period is the later of two years after manufacturing of the model permanently ceases, and two years after the day the declarant notifies the Minister under section 901.195. CAR 901.201 CAR 901.195
"Later of" is the whole rule, and it has two consequences. A model whose production has ended but which has just been the subject of a 901.195 notification starts a fresh two years from that notification. And a model still in production keeps its records — the manufacturing clock has not begun. CAR 901.201 CAR 901.195
Your checklist
A declarant under section 901.194 has discharged Division XI's documentation side when:
- A maintenance program — servicing and maintenance instructions, plus an inspection program — reaches each user of the model CAR 901.200
- Mandatory actions are handed over as their own deliverable CAR 901.200
- An operating manual carries all ten contents of paragraph (c) CAR 901.200
- Records of mandatory actions, verification results and reports, and — where a service difficulty reporting system is required — investigation results are kept and can be produced to the Minister on request CAR 901.201
- Those records are held for the later of two years after production ends and two years after a section 901.195 notification CAR 901.201
| The duty | Audience | Section |
|---|---|---|
| Maintenance program, mandatory actions, operating manual | Each user of the model | 901.200 |
| Mandatory actions, verification results and reports, service difficulty investigation results | The Minister, on request | 901.201 |
Where people go wrong
| Symptom | Likely cause | What to do |
|---|---|---|
| A question asks which documents the maintenance program contains | Mandatory actions look like part of it | Paragraph (b) is a separate deliverable CAR 901.200 |
| A draft manual gives maximum altitude and maximum velocity only | The section states a range | Give the minimum and the maximum, for each flight phase and mode, in normal and emergency conditions CAR 901.200 |
| A manual covers protecting the public but not the crew | Paragraph (c) has two injury audiences | Cover the crew's severe-injury characteristics as well CAR 901.200 |
| Retention is counted from the day of the declaration | The section names two other dates | Use the later of production ceasing and the 901.195 notification CAR 901.201 |
| Verification test results were never sent to Transport Canada | The duty is to keep them, not to file them | Retain them and produce them on request CAR 901.201 |
Test yourself
Sources
- CAR 901.194 — Declaration
- CAR 901.195 — Notice to the Minister
- CAR 901.196 — Issuance of Acceptance Letter
- CAR 901.197 — Establishing a Service Difficulty Reporting System
- CAR 901.200 — Documentation
- CAR 901.201 — Record-keeping