SAFA Ramp Inspections - Code7700

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SAFA Ramp InspectionsGuidance materialWhen following the procedure as described in chapter 4.2 f) below, the category 2 findingsraised (failure to identify, report and or assess significant technical defects) should begrouped as long as it concerns the same system and “root cause”; if not, findings should bereported separately with the exception of missing fasteners. The number of (out of limits)missing fasteners (and therefore the related category 3 findings) found during oneinspection could be considerable. However, this high number of cat 3 findings would notreflect the perceived impact on safety. Therefore, findings on missing fasteners in theprimary structure should be grouped and reported as one finding; the same for the missingfasteners in the secondary structure.With regard to non-compliances on missing fasteners, findings can only be raised if themaintenance documentation contains clear limits and/or dispatch conditions. In theabsence of such clear manufacturer standards, inspectors should only raise findings if theirexpert judgement (possibly supported by licensed maintenance personnel) is such thatsimilar circumstances on comparable aircraft would be considered to be out of limits.A SAFA ramp inspection aims at assessing the compliance with the applicable internationalstandards of an aircraft used in operations. It should be noted that several other entitiesare playing a crucial part in this process, such as the authority of oversight of the AOC, theauthority issuing the flight crew Licences, the authority of oversight of the airworthiness ofthe aircraft. Therefore, some non-compliances may be highlighted in fields where theinspected airline may not be the responsible entity (e.g. issue of certificates of registration,issue and oversight of the AOC or Licences). Nevertheless, as part of the ramp inspectionprocess, these non-compliances will be raised by the inspectors in accordance with theSAFA ramp inspection procedures, and recorded as such in the final report of the airline’sinspection.When inspectors are raising issues on the ramp that may lead to the identification offindings, they should, as much as possible, document and keep records of the noncompliancesdetected. This could be done, for instance, by taking pictures of the deficiencyitself, as well as pictures of the manufacturer references used to assess the technicaldefects, pictures or copy of the TLB entries performed. These elements could be very usefulin the follow-up phases of the ramp inspection either to explain in details and illustrate thefinding detected, or to be able to exchange appropriate documented evidence whenfindings are challenged.Note 1: In exceptional cases, a single fault may give rise to more than one finding underdifferent inspection items, for example: a tyre worn beyond limits whilst the commanderrefuses to enter the defect in the Technical Log (or equivalent) would give rise to findingsunder C04 and A23.Note 2: On manufacturer standards, a finding to these standards should always bedemonstrated in relation with aircraft technical documentation (AMM, SRM, CDL, SWPM, etc.)and MEL references. If significant defects are suspected, the operator should be asked todemonstrate compliance with the standards. Deviations from these standards can only beacceptable if the State of oversight has issued a formal waiver/concession detailing conditionsand/or limitations to allow the aircraft to continue to operate for a specific period of timebefore final repair, unless the aircraft will perform a ferry flight and the validity of the CofA isnot affected. In case the deviation leads to a temporary invalidation of the Certificate ofAirworthiness, the operator will be required to obtain a permit to fly from the State of Registry,and the relevant permission from the affected States (departure, arrival and every overflownStates).SAFA Coordination Section Page 16 of 217© European Aviation Safety Agency, 2012 V 2.0
SAFA Ramp InspectionsGuidance materialNote 3: Certain States may have national standards applicable to foreign operators whenoperating in their territory. Deviations from such standards should be reported as findings onlyif:- the national standards have been published (e.g. AIP) and are applicable to foreignoperators flying into their territory;- a deviation from those standards has an impact on safety.For such findings the report should indicate ‘N’ in the column Std. and the appropriatereference should be included in the column Ref.Any other deviation from national standards which does not have an impact on safety (e.g.insurance certificate in USD instead of SDR) should be recorded as cat. G (General Remark).A participating State should issue internal procedures for the use of its inspectors on whatnational standards and how compliance with those standards should be checked, and how anypossible findings should be categorised.4.2 Detection/reporting/assessment of significant technicaldefectsA technical defect is considered to be any material fault pertaining to the aircraft, itssystems or components. Minor defects are typically without influence on safety. Althoughminor defect are not considered to be findings, they should be brought to the attention ofthe operator using general remarks (cat. G). Those defects which are potentially out oflimits are considered to be significant defects. Further assessment is required to determineif the significant defect is within or outside the applicable limits. Such defects should beknown to the operator since they should have been detected during regular maintenance,aircraft acceptance procedure or pre-flight inspections.Care should be taken when dealing with technical defects which did not necessarily had tobe detected by the operator since the approved maintenance programme (AMP) does notrequire the operator to detect such issues during turn-around inspections; examples aremissing fasteners, bonding wires and the cabin emergency lighting which are normally notpart of the pre-flight inspection. Therefore, no finding should be raised under A23/A24 thatsuch defect was not detected/reported/assessed. However, inspectors should not ignorecases where those defects led to an out of limits situation; apparently the AMP failed toensure that the aircraft is in an dispatchable condition and therefore such non-complianceshould be raised as a cat. 3 finding.Since significant defects might have appeared during the inbound flight, the inspector mustgive the operator the opportunity to identify and assess a significant defect during thepreflight inspection before he raises a finding. However, this does not mean that theinspector should wait with his inspection of the aircraft condition until the operatorperformed/completed the preflight inspection.A “defect within limits but not recorded” should not be raised as a technical finding. If thesignificant defect appeared to be within limits, the safety focus changes from the defectitself to the concern that the defect was not detected/assessed by the operator.The following procedure should be used (see also the flowchart below) in particular wheninspecting the Aircraft Condition. In addition, the same procedure may also be appliedwhen inspecting items A, B or D:a) If time allows, the inspector should inspect the aircraft condition after the operator hascompleted the preflight inspection.b) The inspector may perform the aircraft condition inspection (C-Items) in advance of theoperator’s inspection in order to make best use of the time available for the wholeSAFA Coordination Section Page 17 of 217© European Aviation Safety Agency, 2012 V 2.0
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