Providing online training for business aviation professionals globally.


A Plan For Canadian Private Operator Non-Type Training Requirements

Regs, SMS | December 21, 2015

Author: Scott Macpherson

At the 2014 CBAA Convention in Edmonton, distributed a document comparing the non-type specific training requirements (topics and periodicities) of CAR 604 to those of the CBAA BAOSS and CASS 724.115. This analysis showed that CAR 604 is the most demanding training environment in Canadian civil aviation, period.

Actually, though it was not illustrated in the analysis, CAR 604 non-type training requirements exceed any other regulatory requirement worldwide. In addition, unlike the enlightenment being experienced in other jurisdictions related to tying training activities to operational data such as C-FOQA indicating actual operator risks, CAR 604 is a step back into pre-SMS days of prescription that does not acknowledge differences between operators’ risk profiles, despite the claims of Transport Canada to the contrary.

There are three CAR 604 divisions of particular relevance to non-type training, such as the training provided by

1) Division IV regarding operator Special Authorizations is effectively comprised of CAR 604.46 to .60 and .74, such as 604.49 Take-off Minima or 604.58 RNP4 Requirements.
2) Division IX regarding Personnel Requirements is effectively comprised of CAR 604.139 to .149, nearly all of which concerns training such as CAR 604.147 Ground and Airborne Icing Operations Training.
3) Division X regarding training programs.

CAR 604.139 says that:

“(1) Subject to subsections (2) and (3), for the purposes of this Division and Division IV, the validity period of any training, any competency check, or any pilot proficiency check expires on:

(a) In the case of training in the performance of the emergency procedures referred to in subsection 604.169(2) and in subparagraphs 604.179(z)(viii) and (ix), and the high altitude indoctrination training referred to in Section 604.176, the first day of the thirty-seventh month after the month in which the training was completed;
(b) In the case of all other training, the first day of the thirteenth month after the month in which the training was completed.” (cited from CARs Deluxe, an indispensable service)

This seems straightforward enough and doesn’t apply to Division X, at first blush. However, it is clear from CAR 604.139(1)(b) that Special Authorizations, Ground and Airborne Icing, SMS, and all prescribed training for roles such as flight follower require prescribed annual training, which is a significant additional training load alone when compared with current BAOSS or CASS724.115 training requirements.

Some Division X pilot training elements, such as CAR 604.169(1)(a,k,l, and n), are “incorporated by reference” by and therefore subject to CAR 604.139(1)(b) and CAR 604.143(1)(b)(i).

All this detail, of which there is much more, is to say that many training elements are required that have never been so before. Most of the new requirements are almost certainly a mistake, but no one at Transport Canada seems to have the inclination to fix the problem.

If you have any concerns regarding these new requirements or how we plan to assist you in meeting them, we would welcome a call from you to ensure that we set up the best possible program for your needs. Please note that these requirements will significantly increase your training load unless you choose to engage Transport Canada in a fight for more reasonable regulations. Some of our clients have chosen to simply comply and get on with flying. Others have chosen to maintain their training in accordance with their demonstrated risk profiles and are willing to have a disagreement with Transport Canada at some future date. We need to know your appetite for risk in order to set up your programs according to your wishes.

Suffice it to say that if an operator has all available Special Authorizations approved and fits an average operational profile, their training program could triple in frequency from one lesson every 8 days to one every 2.5 to 3 days, without risk indications to support such a training load, and therefore without safety benefit.

By recognizing topics that clients have completed and carefully considering associated risks and whether the training continues to provide mitigation of those risks, we have been able to minimize the increase in training load for our clients while preparing them for the 01 June 2016 end of the exemption from elements of CAR 604. We sincerely hope that there is a lightening of the regulatory load by then, but I suspect that we have run out of time as a community. will continue to seek means by which to assist you.

02/05/16 UPDATE:

Since this blog entry, the CBAA has announced that Transport Canada has extended the CAR 604 PORD exemption (available to operators that previously held CBAA POCs) to at least December 1, 2016. This significantly relieves the pressure on our CAR 604 clients who otherwise would have been required to meet all the requirements by June 1st. The training required can now be spread out over at least another 6 months, during which time it is our sincere hope that TC will find a way to amend the regulation or make an administrative allowance to move past the prescriptive requirements to risk-based training assignment. This would allow all of our clients to continue as they have been: using a formal training needs assessment to tie their training topics and periodicities to real operational risks.


Scott Macpherson is the President and Founder of and Vice-Chairman of the International Business Aviation Council (IBAC) Governing Board. He is currently Captain on a Falcon 900LX.

aviation professional

Engaging and Effective Online Training. Logo
Get a free topic

Required fields are indicated with a red star.

Request a free demo

Required fields are indicated with a red star.