Registry aircraft inspections:
‘Not just kicking the tyres…’
So, you have acquired a business jet and chosen a registry. What should you expect from the registry’s aircraft survey? Words: Mike Stones
“KICK THE TYRES and light the fires.” That’s mythical fighter pilot language for pre-flight inspection of the landing gear before igniting the jet’s afterburners for a short take off. But aircraft surveys carried out by registration authorities will be more demanding than undercarriage inspection, according to the five leading registries we consulted. Both the inspection checklist and the inspection process have changed significantly over the past 10 years.
David Colindres, president of San Marino Aircraft Registry, says change is continual. “As technology evolves, our inspectors’ checklist changes every year to adapt to newer aircraft or for the integration of technology within our organisation.”
But it is the process of inspection, rather than the checklist, that has changed most for the Civil Aviation Authority of the Cayman Islands (CAACI). P H Richard Smith, its director-general says: “With the evolution of technology and online access to manufacturer and specific aircraft records, surveyors can accomplish a significant part of the process prior to an onsite inspection.”
Nevertheless, the value of the onsite inspection remains key. “The visit validates that the records provided in advance reflect the actual certification and maintenance status of the aircraft,” explains Smith. It also allows for a physical inspection of the aircraft in its operating environment. Crucially, onsite inspection enables CAACI to determine if the organisation operating the aircraft is “equipped and capable of providing continuing airworthiness management”.
Simon Williams, director of Civil Aviation, with the Isle of Man Aircraft Registry (IoMAR), notes the content of the aircraft survey is designed to ensure that the aircraft is compliant with Isle of Man aviation regulations. These, in turn, are based primarily on International Civil Aviation Organization (ICAO) Standards and Recommended Practices.
The main reason for undertaking the annual inspection is to ensure that the aircraft is airworthy and so fit to be flown; this event includes physical inspection of the aircraft, accompanied by a detailed document review.
For the Guernsey-based 2-REG Aircraft Registry, inspections changed in 2016 when it started to issue Air Operator Certificates (AOCs). This required aircraft surveys to take into account airworthiness elements of specific approvals like Reduced Vertical Separation Minima (RVSM), High Level Airspace (HLA) and Extended-range Twin-engine Operational Performance Standards (ETOPS).
The registry’s Michiel Dek, who is its development & safety manager/ airworthiness surveyor, says: “The latest development is digitalisation of the surveys by completing surveys with our new software tool EMPIC.” The tool is a central software solution to manage and check the implementation of specific aviation regulations. 2-REG requires aircraft to be registered with it before conducting any airworthiness survey.
The Registry of Aruba’s chief operating officer Alexandria Colindres says: “The main change is that the airworthiness inspection for the issue or renewal of a Certificate of Airworthiness has to be fully documented and internally audited.”
Aruba requires the initial registration airworthiness survey to ensure that an Export Certificate of Airworthiness, or equivalent document, has been issued by the last state of registry (valid for 60 days after its issue) and that the Type Certificate Data Sheet (TCDS), upon which the aircraft is based, has been accepted by its Department of Civil Aviation (DCA).
Photo courtesy of L.J. Aviation
Photo courtesy of Duncan Aviation Inc
Check out the checklist
The location of the aircraft presented for inspection is important. It must be positioned at a location to enable an adequate inspection – usually a maintenance organisation, says David Colindres. Also, a source of power – either from the aircraft or a ground source – must be available.
The depth and areas of the inspection are at the discretion of the CAA’s airworthiness inspector. “But as a minimum, it should provide for the ability to inspect the external fuselage, wings, tail-plane (with flaps lowered), cargo holds, avionic bays, engines (with cowls open), flight deck and cabin with external electrical power to the aircraft.”
A person should be present, representing the applicant, who can perform maintenance functions and certify such things as panel removal replacements, door opening, functioning of equipment etc.
2-REG Aircraft Registry says it bases inspections on two elements: a survey of the aircraft’s technical records and a physical survey of the aircraft to check for any inconsistency between the plane and its records. “A survey consists of an investigation of the aircraft history ‘back to birth’, says Dek. “Compliance is checked against the aircraft TCDS, aircraft maintenance programme, airworthiness directives for airframe, engines and appliances and propellers if applicable.”
Also, aircraft repairs and modifications are checked for compliance with the Guernsey requirements (GARs). Component lists such as hard-time lists – covering components that require a specific action at specific intervals – are verified against the aircraft. The physical inspection is concentrated on finding any damage, leakages and other non-conformities. A check of the Aircraft Flight Manual status, aircraft software and databases and required instruments and equipment are surveyed.
IoMAR lists the key items of an airworthiness survey checklist as being: Type Certificate, airworthiness directives, modifications, life limited parts and logbooks. Like 2-REG, all IoMAR aircraft are surveyed after registration. CAACI’s checklist appears at the end of this article.
Provided the physical inspection of the aircraft and its associated records are satisfactory, at the San Marino Aircraft Registry the airworthiness inspector will make a recommendation to the CAA that the certificate of airworthiness may be issued.
But what happens when inspections reveal problems? The first thing to note is that inspection failures are rare.
“Surveyors can accomplish a significant part of the process prior to onsite inspection.”
P H Richard Smith, Civil Aviation Authority of the Cayman Islands
Both the surveyors’ checklists and inspection processes have changed significantly over the past 10 years.
‘Meeting the required standard’
Williams, from the Isle of Man Registry, says: “The number of aircraft not meeting the required standard when presented for survey is now very low and there is no common denominator regarding the reasons for generating airworthiness findings. IoMAR has worked very hard in close cooperation with industry to ensure that when an aircraft is presented for survey, the documentation and aircraft are properly prepared in anticipation of a thorough inspection. If findings are generated, there is a standard process for working with industry to close those in an appropriate fashion, such that the aircraft is returned to service in a timely, efficient and ultimately safe manner.”
Colindres, from San Marino Aircraft Registry, agrees. Fewer than 2% of aircraft do not meet inspection standards. “Very few aircraft do not meet our airworthiness requirements. The registry attracts first-class operators and aircraft.”
If deficiencies are found during the inspection, the airworthiness inspector will raise findings for the airworthiness coordinator or maintenance postholder to correct. When findings have been corrected, evidence of the corrective actions must be supplied to the inspector. This includes copies of logbook entries, copies of documents, photographs etc for his or her review and agreement that the finding is closed.
“It’s very important to highlight that for an operator or aircraft owner to achieve compliance, the person presenting the aircraft and its records would normally be the operator’s Airworthiness Coordinator or Maintenance Postholder in the case of aircraft operated commercially,” says David Colindres. “This person is responsible, and must be competent during the inspection, for ensuring that the aircraft and its associated records are available for inspection and meet CAA San Marino Registry standards and requirements.”
Dek from 2-REG says that his registry never “rejected” an aircraft, but all aircraft surveys have findings. “The airworthiness surveyor opens findings against the aircraft which have to be resolved by the aircraft’s owner and maintenance organisation,” says Dek. “After findings have been satisfactorily closed the airworthiness surveyor writes his closure report. On that basis the Certificate of Airworthiness can be issued. Sometimes the number of findings is limited to a couple of findings and, incidentally, there may be many findings.”
“We issue a Certificate of Airworthiness in digital format.”
Simon Williams, Isle of Man Registry
Findings vary from an aircraft’s physical factors to incomplete records or overdue maintenance; the most common being improper documentation provided to the surveyor. The lead time to close these findings depends on the level of findings and the maintenance required to fix them. If an aircraft does not fully comply with the airworthiness or operational requirements, 2-REG may issue a ‘Permit to Fly’ to move the aircraft to a location where remaining maintenance or repair can be performed in order to issue a Certificate of Airworthiness.
Smith, from CAACI, believes the idea of aircraft failing inspections is unhelpful. “The concept of a survey ‘failure’ is misleading. If an aircraft presented to the authority is not fully compliant with either the governing Type Certificate or the OTARs [Overseas Territories Aviation Requirements], these issues are raised as findings. The CAACI works with the aircraft’s owner/operator to correct or mitigate the findings so that a formal Certificate of Airworthiness may be issued.”
Colindres at Aruba says an airworthiness certificate can be delayed by a number of factors. Those include: the application of registration markings, programming codings for the Emergency Locator Transmitter (ELT) and Mode S Transponder and checking the operation of Flight Data Recorders (FDR) and Cockpit Voice Recorders (CVR).
“The owner’s airworthiness coordinator is formally provided with a copy of the inspection findings and then he/she needs to address any findings to the satisfaction of the DI and Aruba DCA prior to the issue of a Certificate of Airworthiness,” says Alexandria Colindres.
Also the owner’s airworthiness coordinator needs to be fully trained and experienced in the aircraft’s continuing airworthiness and confident when working with airworthiness inspectors, stresses the registry.
Annual airworthiness inspections
Certificates of airworthiness generally last one year and initial inspection is followed by annual renewals. Private aircraft may be inspected every 24 months, if they hold a Continuing Air-worthiness Management Organisation agreement with European Union Aviation Safety Agency (EASA) Part M or United Arab Emirates GCAA Part M.
Dek at 2-REG points out: “As a large part of the business is concentrating on transfer of aircraft between owners, operators or lessors a high number of surveys are initial surveys on aircraft that remain with 2-REG for less than one year, after which they continue to another registry to be operated for an airline.”
2-REG reports to the Guernsey registrar and Channel Islands Director of Civil Aviation (DCA). All surveys are conducted by 2-REG on behalf of the Channel Islands DCA. “These are initial Certificate of Airworthiness surveys, Renewal Certificate of Airworthiness surveys, Export Certificate of Airworthiness surveys and Permit to Fly airworthiness surveys,” says Dek. “SGI Aviation [2-REG's parent company] has a pool of about 20 airworthiness surveyors based all around the world to facilitate airworthiness surveys globally.”
For San Marino, all surveys are conducted by the country’s Civil Aviation Authority’s Designated Airworthiness Inspectors.
IoMAR has both in-house surveyors and a contracted provider. “Surveys are frequently carried out by surveyors who reside in the country where the aircraft is based, thus optimising time, cost and efficiency. Following satisfactory survey completion, we issue a Certificate of Airworthiness in digital format to minimise any subsequent delay to the aircraft being operated; this has the added benefit of eliminating courier costs and delays.” says Williams.
CAACI reports that all initial and recurrent aircraft surveys are conducted by individuals employed and trained by the Civil Aviation Authority of the Cayman Islands worldwide. “This ensures that the regulatory service provided meets our organisational standards and the aircraft are measured referencing the applicable airworthiness requirements consistently,” says Smith.
So, whichever registry you choose, be prepared for aircraft inspections to consist of far more than simply ‘kicking the tyres’.
Registry of Aruba,
Chief operating officer
+1 305 471 9889
San Marino Aircraft Registry, President
+39 054 994 1539
2-REG Aircraft Registry, Development & safety manager/ airworthiness surveyor
+44 330 828 0875
P H Richard Smith
Civil Aviation Authority of the Cayman Islands, Director-general
+1 345 949 7811
Isle of Man Aircraft Registry,
Director of Civil Aviation
+44 162 468 2358