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Important Notice for Canadian CAR 604 Operators

Regs | April 6, 2016

Author: CBAA

Some TC inspectors continue to tell CAR 604 operators currently certifying pilot competency using a training to proficiency program, in accordance with the requirements of BAOSS Section 4.8 b., and as permitted by the current CAR 604 exemption, that they will need to have a CAR Part VII PPC or a CAR 604 PCC completed on every pilot they use if they are to continue to fly after the current exemption expires. This is categorically incorrect! Competency certification based on a BAOSS training to proficiency program under the current exemption is valid for TWO years. For example, if you completed the program on 31 May 2016, the pilot competency certification (not annual training requirements) and the IFR are valid to 31 May 2018. Certification is documented in accordance with BAOSS Section 4.11 e. Since there is no need to get an IFR renewal now that IFRs do not expire; there is an additional certification documentation requirement for CAR 604 pilots since there is still an IFR validity documentation requirement. Respecting pilots under a training to proficiency program, certification of IFR competency shall be entered in the holder’s Aviation Document booklet on the Competencies Record page by whoever certified pilot competency under BAOSS Section 4.11 e. If TC inspectors have any questions on this interpretation of requirements, they are to be directed to Deborah Martin, Chief Commercial Flight Standards, the author of the advice provided above, at or 613-990-1055.
Those doing training to proficiency are advised not to do a PPC or PCC based solely on advice from TC (ie that the training to proficiency competency certification expires when the exemption expires) because it may become an obstacle to transition to the training to proficiency program defined in an exemption currently under final review at TC. This training to proficiency exemption, its accompanying Advisory Circular (AC), an extension to the current CAR 604 exemption taking it from 31 May 2016 to 30 November 2016, CAR 604 guidance material (in an AC) and specific SMS guidance material are all in final draft form and are expected to be provided to operators by the end of May if not sooner. The CBAA has been or will be fully consulted on these documents.

Please direct any question you have on this information to Merlin Preuss @ or call him @ 613 883 77387.

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