CAA and Light Aircraft

[WorkingHard]

I read an item in a thread recently about some apparently nit picking requirements by a CAA surveyor and thought it may be interesting to get the facts from people about their experiences. So if you have a tale to tell (first hand please) then lets hear it. It would be good to hear the nicer side as well if there are any such tales. For example we have the idiotic "threats" to ground aircraft that have not updated the insurance because of the falling value of the £. Does this also apply to those with an AOC?

[Mike Cross]

I've had dealings recently with a number of people from the CAA regarding Lee on Solent. They all went out of their way to be helpful and we got what we needed with no fuss.

On the other hand I went to a CAA safety evening several years ago where one of the speakers was a CAA surveyor. He was talking about the issues that had come to light as a result of surveys, aircraft found with unapproved mods, unapproved repairs, damage etc. that should not have been flying.

I stuck my hand up and asked "OK so you find an aircraft that has these problems, yet it has a C of A and a C of R issued by an engineer licensed by you. What action do you take to find out why they were issued and where the process failed?"

His answer was "Airworthiness is the Operator's responsibility."

That may be good answer if the operator is a major airline with his own maintenance organisation but not if the operator is an owner who is putting his trust in the system. It's a bit like saying that you must have an MOT certificate for your car but if the testing station passed it when it shouldn't have then it's your fault.

Maybe it's an Airworthiness Surveyor thing.

[jxk]

It's a bit like saying that you must have an MOT certificate for your car but if the testing station passed it when it shouldn't have then it's your fault.I believe, if say your brakes fail the next day after a MOT has been issued there is NO redress on the testing station. If you think about it, the testing station use a rolling road and visual inspection of the brake system but can't anticipate, for instance, a master cylinder failure.

[Karl Bamforth]

Most ppl think and act as though a surveyor is there to make their life difficult.

I have been dealing with the CAA for 20 years I always treat them politely and with respect, I take the attitude that they are there to help me.

On the odd occasion that they have noticed something I have missed, I was honest that it had slipped through my inspection and ask if they have any recommendation as to what I need to do to meet their requirements.

They have always been helpful and never refused a CofA or felt a need for a return visit.

On the other hand I have seen ppl argue with them, shout at them and one guy even threatened to sue. It never works.:=

[Rod1]

The CAA recently “audited” my LAA aircraft. They spent about 2.5 hours on the paperwork, and the same on the aircraft. They were polite and friendly and I got a letter thanking me for my cooperation and advising there were no issues. If you follow the rules and keep your paperwork up to date you will have no problems.

Rod1

[XX621]

Interesting thread.

I know of an aircraft which has a CofA but has had a couple of unapproved repairs - and for good reason. Details of how to make the "approved" repair never arrived from the manufacturer, despite asking repeatedly, and they eventually went into liquidation.

It was only a 1hr job to a seat, nothing to do with powerplant, structure, or flying controls.

I was told some "approved" repairs no longer need to be done by an approved engineer under EASA and this was one such case.

Comments welcome.

[Duchess_Driver]

Unfortunately, unapproved repairs to seats is probably a bad example, 621......

What happens if your unapproved P1 seat rail modification fails at rotation?
What happens if your seat crumples on a 'firm' landing, or your seat back latch mechanism fails.....????

I don't know much about engineering issues, which is why I leave it to the CFI and the maintenance organization to decide what gets done and when.

[Dr Jekyll]

If my seat rail repair failed at rotation I'm not sure having a piece of paper saying the repair was approved would be make me feel much better.

[WorkingHard]

"If you follow the rules and keep your paperwork up to date you will have no problems"
There speaks a man who knows all the rules then! Sorry Rod1 but it is often not so easy, especially when the CAA will not or cannot give you a precise definition of something. You are then left with, and I quote, "submit your paperwork and we will make a ruling then" How does that aid safety? Would it not be better to have a definitive answer first, in writing, so that you have the comfort of following the rules. Problem with that is then someone has to sign something that may, just may, be prejudicial to some unforseen circumstance in the far distant future and the CAA just cannot be put in that position.
Cynical? who me?

[Romeo India Xray]

Would it not be better to have a definitive answer first, in writing

I have no idea with relation to maintenance, but I would imagine that under EASA it is not a million miles removed from the JAR-FCL and EU-OPS that I am involved with on a daily basis.

If this is the case then there are so many aspects that state "to the satisfaction of the authority". Henceforth we get into a chicken and egg situation. Obviously the authority is not likely to have the resources to develop your particular major or minor mod for you, so it has to be done in this manner.

Like I say, this holds especially true in my personal area of expertise, FCL. JAR FCL states that all jet types must have a type rating, it also provides a handly little list of every type rating. What do you do when the jet aircraft that you wish to fly is not on the type rating list and yet the rules tell you that it must have a type rating? In the UK with lots of ex military jets you have a nice little publication to tell you what to do, for the rest of us with no experience in this area, we have t INTERPRET.

Certainly with our NAA, if you are prepared to work with them, consult them, listen to them and follow their guidelines, then you will have a very easy time. If you want to make it up as you go along, then expect no single stone to be left un-turned.

RIX

[Karl Bamforth]

One of the reasons organisations like the CAA try not to state exactly what is required but just state what the end reslut must be is to be flexible.

Most engineers will comply with an AD as it is written but when appropriate they had a statement something like "or alternative means of compliance acceptable to..........."

Although rarely used this allows an engineer who has a better and/or cheaper idea for compliance can do so as long as it is acceptable.

Some time ago I received an AD that required a 300 quid part plus 5 manhours to replace it, it was intended to prevent failure due to chaffing. I managed to show that minor re-routing and application of 2 quids worth of plastic trim would effectively make chaffing impossible thereby meeting the alternative clause. We saved over 300 quid for the owner. The manufacturer wanted to hear nothing of it but the CAA accepted the alternative compliance.

With reference to the seat repair, I think it is quite obvious from this thread as to why it needs a piece of paper approving it. The statement "nothing to do with powerplant, structure or controls" displays that the author has missed the dangers of a seat failure.
The piece of paper would show that the correct investigation and calculations have been performed to demonstrate strength and reliability.

XX621 please get it checked out.

[IO540]

There is a list of approved pilot maintenance (similar though not identical for G and N-reg) and those items the pilot can do himself. This I believe includes seat upholstery repairs.

[scooter boy]

The most nitpicking fool I ever encountered was a PFA inspector (about 7 years ago).
He had not been engaged by me to inspect my aircraft but just happened to be in the hangar where my (then) Europa was kept - apparently with a measuring tape, a penchant for crawling around hangar floors and a little spare time on his hands.

He left a note for me inside my aircraft because the lettering on the wing of my aircraft was 1" too small. It should be amended immediately.

Of course I took immediate action, did sweet FA and laughed my socks off!!!

Good to know that although most CAA, FAA and PFA(now LAA) inspectors are sensible, pragmatic people there are still some jobsworths out there.

SB

[IO540]

I think that things are changing for the better. The CAA can see that EASA is going to push out a lot of their functions so they need to be more customer-friendly.

In 2002, when my TB20 was new, the initial CofA inspector demanded that the IFR GPS (which was IFR BRNAV certified by Socata) is disabled for IFR and only VFR features are enabled. Of course I got that changed back (privately) afterwards, as the IFR function was on the CAA approved type certificate!! He then stuck EXIT stickers on the doors (yeah, the doors on a TB20 are really hard to find), and stuck an INOP sticker on the prop TKS on/off switch because he didn't think a prop-only TKS is "official". That sticker was obviously removed the moment he left. So.... a complete waste of space really.

I don't think they do that sort of thing today.

But their past attitude to e.g. IFR GPS has created a huge legacy of noncompliant installations which cannot be approach approved because they were put in for VFR only (because "everybody" thought that GPS is illegal, or illegal for IFR, etc) and don't have the proper indicators in the right place.

[WorkingHard]

I see the CAA is being castigated by maintenance organisations now over fees.
here http://www.pprune.org/private-flying/354408-part-m-owners-subpart-g-f-companies-watch-out.html