Protocol for reciprocal inspections of maintenance facilities

[Trim Stab]

I fly an EASA registered aircraft in Nigeria, operating on an Nigerian CAA AOC. We intend to fly the aircraft back to France for maintenance, then return to Nigeria.

The NCAA insist that we obtain a Schengen visa and pay (flights, hotel) for an NCAA official to "inspect" the maintenance facility in France to verify that it meets "Nigerian standards".

Can anybody advise what our obligations are? My initial reaction is that since the aircraft is EASA registered and the maintenance is being undertaken in an EASA facility we should have no obligation to organise their "inspection". They would, of course, be in their rights to insist that they inspect the aircraft once it is back on Nigerian territory. I would also imagine that if the NCAA do want to inspect the maintenance facility, they would first need to get authorisation from the French DGAC?

Thanks in advance for any help.

[Capot]

Almost certainly, without looking it up, the realities are that the "inspection visit" is just an excuse to a free trip for someone and that, none-the-less, you will have to provide it to avoid a confrontation. If you want to operate in Nigeria, it's best not to make a fuss. They will win in the end.

The UK CAA are by no means above doing the same thing; spurious visits to training facilities in agreeable places is one example I know about, and I suspect that some Line Maintenance facilities have been "inspected" unnecessarily.

My advice would be to go along with it, and try and keep the cost down as much as possible. That's how to deal with the UK CAA when they fancy an unnecessary expenses-paid trip, and is probably best for the Nigerian equivalent as well.

[Trim Stab]

Capot, thanks. Yes, it is obviously a shameless freebee but am trying to find an excuse to make it not possible without then having life made too difficult back in Nigeria. We do not have a European office or address, so we cannot issue a letter of invitation for the Schengen visa. The NCAA's retort is that the maintenance facility will have to provide a letter of invitation. The maintenance facility are, of course, not keen to do this because they do not want to take responsibility for him, nor do they particularly want him on their premises anyway. Does the maintenance facility have any obligation to provide an invitation?

The solution I am hoping for is that the correct protocol is that the NCAA has to write to DGAC to request permission to visit the facility. If the permission to visit is granted, then the facility can issue a letter of invitation for the visa. If I can find that in writing, then I know the NCAA will quietly drop the subject, because they will not want to write a letter to DGAC.

[Capot]

I'm in unknown territory here, but I would be very surprised if there's a protocol for the visit to be "sanctioned" by the DGCA. I'm thinking of MRO's in the UK with multiple approvals from non-EASA administrations and I don't recall the UK CAA, or indeed EASA, being asked or even told about inspection/audit visits from the other administrations, which they would regard, I would have thought, as nothing to do with them.

It is possible, I suppose, that most would let the CAA know as a matter of courtesy only, but not doing so would not affect the visit.

I also suppose I am probably wrong, but I'm sure someone who actually knows about it will respond.

As an aside, if I were you I would suggest to the MRO concerned that they do all possible to help you, their customer, rather than be obstructive. But then I never learned how to be emollient.

Edit: Afterthought; I'm barking up the wrong tree, talking about "Approvals" from other administrations. Sorry! Visiting to inspect the MRO, essentially for its compliance with Part 145, is a different can of worms, and all bets are off. But there's nothing to stop the MRO inviting the Nigerians to look around any time they want to, it's their train-set. Maybe they should just do that and help with the visa invitation, in your interests as a customer.

[matkat]

As the aircraft is EASA registered and maintained under a 145 approval cannot see why the NCAA would require an oversight, tend to agree that this looks like a blatant 'jolly' request however it maybe that the NCAA AOC says different.

[bcgallacher]

I have been involved with the NCAA on a few occasions - usually all difficulties can be resolved with a private meeting where the amount of cash required to make the problem go away can be agreed on. Dr D the erstwhile head of the Nigerian authority had very deep pockets.

[Capot]

Just as an afterthought to this thread; the subject of global recognition of facilities was on the agenda at an EASA Conference in Cologne earlier this week.

Essentially, it's all about EASA negotiating Bilateral agreements ("BASA"s) with other administrations, eg USA, Canada, Brazil, China and so on, for mutual recognition of each side's approved organisations and licences. This has been going on for a while, starting with N. America, but is obviously a slow process.

I suspect that Nigeria might be some way down EASA's list of priorities, but perhaps I'm wrong. The level of mutual confidence might need to be nudged upwards a notch or two before an agreement can be concluded.

And then there's all those nice freebies for "inspections"; we wouldn't want to lose those, would we?

[grounded27]

Reciprocity with other countries is quite common in all matters of regulation. It is simply Nigeria being a pain in Frances ass because the French want to make it difficult to outsource maintenance to Nigeria. Same goes with visa's, tariff's etc.

Many moons ago I had heard stories of a Central American MRO that would offer to sign off a c-check package of a FAA registered aircraft if the airline simply flew the aircraft down and let them close the hangar doors behind it for a few weeks. It is garbage like this that starts the trend.