I spent this morning flying with a certain flying school, who I personally think are pretty well managed and run, with fairly decent aeroplanes.

One thing that school does is have all of the aircraft manuals, correctly amended, on a shelf accessible to everybody. And, quite rightly, students are encouraged to read them! Usually sat there with a coffee. All, in my opinion, excellent practice.


Now, when I returned from my flight, there was a CAA inspector who'd turned up to ramp (actually paperwork) check a selection of aeroplanes, including the one I'd just flown.

Going through the paperwork, he commented to the manager of the school in my hearing that they were probably routinely illegal, since they weren't flying with the POH on board and accessible to the captain.

Now, I know this is a rule in the USA, but I don't recall it ever being a rule in the UK? So I asked - and was told that since 2008 when EASA took over most of GA, they've taken on foreign flight manuals without any amendment - and so if the FAA manual (e.g. all Pipers and Cessnas) says the manual must be kept within the aircraft, then that is now the law. The CAA chap claimed this was buried in EASA regulations and calmly told me that I'd therefore just flown illegally (in a manner which politely indicated however that because he was such a nice chap, he wasn't going to take action over it).


We then had a healthy argument about the safety benefits of the manual being in the aeroplane, versus the flying school, before he politely told me to clear off and let him get on with his job - which I had to do anyway!



I've just had a look on the CAA's website, where I can find nothing stating this (e.g. the documents section of the safety sense leaflet on airmanship) I then went to my CPL course notes and find that there is a requirement in JAR-Ops-1 to carry the POH. However, JAR-Ops-1 only applies to commercial air transport over 10 tonnes, not to me flying privately or even so far as I know to pretty much any flying training.


So, was he right and I'm flying illegally? If so has anybody actually been telling us this? I *think* I'm more informed than most about GA airworthiness, and it really is the first I've heard of it as a light aircraft legal requirement within the United Kingdom.

G

My POH lives in the aircraft and I have always been under the understanding it had to be there.

sounds like you handled the situation well, but if the flight had been commercial (AOC) then you would have been bound by EU-Ops, not JAR-Ops.

Anyway, it was a private flight so go to ANO:-

Article 86 (2) refers to Schedule 10
Article 86(3) States that if a private flight begins and ends at the same aerodrome as does not pass over the territory of any country other than UK, then Flight Manual can be kept at the aerodrome.

When people (CAA inspectors or others) challenge me on regulations, I usually thank them for their advice and politely ask them to point to the appropriate document so that I might read it for myself. If I am wrong or just didn't know, then I have learnt something. If not.....

Just looked up EU-Ops...

So, assuming that flying school operations (I was getting some instruction) comes under EU ops - which isn't explicitly either stated or denied, presumably the question is whether EU-Ops, or the ANO takes precendent?

As it happens, I also just looked up Appendix 1 part B, and the school have their own student manuals (approved by CAA for CPL training purposes), which contain everything in Appendix 1 Part B. So presumably they only actually need to carry one of those for non-private flights?

G

Oooh, Genghis vs CAA flight ops inspector. I'd love to have been in that room

Actually, it's probably best to go to an up to date copy of the ANO - 'Documents to be carried' is now dealt with by Article 150.

Article 150(2) states that an aircraft registered in the United Kingdom must, when in flight, carry documents in accordance with Schedule 9. Schedule 9 lists the documents to be carried on a public transport flight, an aerial work flight and a private flight which is international air navigation. Significantly, it does not mention at all a private flight which is not international air navigation, meaning that there is no legal requirement to carry any documents on such a flight.

There are no EASA documents yet in force that relate to either private or aerial work operations. EU-OPS is relevant only to public transport flights and so, in the case of flight instruction, which is aerial work, ANO Article 150 still applies. The documents referred to in Scedule 9 in respect of an aerial work flight do not include the POH/Flight Manual/etc. and so you were acting perfectly legally.

mykul10 gives good advice - in cases such as this, ask the inspector to quote you the appropriate reference. In my experience they will often be unable to do so because they are basing their statements solely on some misunderstood comment they've heard around the corridors of the Belgrano. It would be interesting to know whether this individual was a Flight Operations Inspector, a Licensing Standards Inspector or a Surveyor.

EU-OPS covers commercial air transportation only, not flight training.

As far as the situation on POHs go, it's a fun question.

The ANO Schedule 9 says (in note b):

"An EASA aircraft is required by virtue of Part 21 to carry its certificate of airworthiness or restricted certificate of airworthiness during all flights."

It also says in para 3:

"If the certificate of airworthiness includes the flight manual for the aircraft and with the permission of the CAA, an aircraft [with an ops manual] need not carry the flight manual as part of [the national certificate of airworthiness]."

Certainly in the past, the limitations set out in the flight manual were considered to form part of the C of A, hence the second comment.

But I don't think the EASA C of A incorporates the flight manual, does it? I don't have one to hand. If it did incorporate the flight manual,

Art 16(7) "An aircraft registered in the United Kingdom with an EASA certificate of airworthiness must not fly otherwise than in accordance with any conditions or limitations contained in its flight manual unless otherwise permitted by the CAA."

would not be necessary, would it? But equally, one could argue that Art 16(7) means that if the flight manual says that it must be carried on the aircraft, then it must.

This debate is time-limited in that EASA OPS will take over from the ANO on these requirements from April 2012. The carriage of the flight manual will be an explicit requirement, though there will be, if all goes according to plan, some helpful alleviations.

Amazing (and funny) how Inspectors from either CAA or FAA are thousands of miles apart but think the same.
The "I've heard it so it must be a rule" attitude.
I usually very politely thank them and ask them to show me the regs they claim to be the gospel. Then we usually get into the discussion where I say "that's not what it says".

As an aside, one of this chap's arguments were that if subjected to a spot-check inspection in France, they would almost certainly impound a (G-registered) EASA aeroplane without the POH on board.

Any truth in that that anybody knows?

G

The flight manual is an ICAO Annex 6 Part II requirement for international air navigation.

2.4.2.2 Aeroplanes on all flights shall be equipped with:
...
d) the following manuals, charts and information:
1) the flight manual or other documents or information concerning any operating limitations prescribed for the aeroplane by the certificating authority of the State of Registry, required for the application of Chapter 2.3;
...

Chapter 2.3 is AEROPLANE PERFORMANCE OPERATING LIMITATIONS.

Of course that's not the same as saying "they would almost certainly impound a (G-registered) EASA aeroplane without the POH on board".

Since 1985, the only times I've ever come across "ARROW" have been in FAA-land.

I still find the UK attitude about POH's quite amazing. Since most of the POH emergency checklists also include an expanded section with additional detail, how is a pilot going to be able to consult it during an inflight problem/emergency if it is sitting on the flying club shelf? Also if the aircraft unexpectedly goes to another another airport how can the pilot do any W & B and takeoff/landing calculations with no manual to consult ?

The POH is not some obscure technical reference document, it is the document that the maker provides to tell you how to operate the aircraft. Why on earth would you not require it to be always carried in the aircraft ?

A thousand letters to the CAA requesting an alleviation from the aforementioned article would likely result in a rule change to prevent the 6% profit margin being eroded by overtime payments.


I would suggest that your typical PPL is going to have a lot more on his mind than thumbing through the expanded QRH during single pilot ops when something untoward occurs. Especially in that either an autopilot won't be fitted or whatever is causing the need for the POH will have probably rendered it u/s.

While the theory of the POH on board is perhaps sound, in practice it is less so, particularly in single pilot private ops. In my experience, the only time I will reach for the POH (FCOM in my case) after using the ECAM or QRH is if I have time (as it is not an insignificant tome - neither is it small on a C172) and the other pilot is concentrating on the "Aviate" part.

I don't think that anybody is arguing that sufficient aircraft data shouldn't be kept on board.

My personal issue is with a CAA inspector apparently making up policy on the hoof (or, equally bad, policy changes being so deeply buried in long documents that nobody's quite clear what they should be doing); if this is to be a rule there are perfectly good ways to publish it, then we all know what we should be doing.

I admit, personally I'd rather see the official manuals kept safe inside a dry, non-flying, building. There's a really clever modern device called a "photocopier" that allows an up to date copy to be kept on board the aeroplane, but if it gets scribbled on, rained on, thrown up on, left behind, or eaten by mice - then it can readily be replaced. Given that the average light aircraft manual is updated about every decade, maintaining document control shouldn't be overly difficult either.

I certainly also believe that either the original or a copy should be kept on the shelf in a flying organisation - then it's possible to access it to plan future flights whilst the aeroplane is away.

G

I doubt the aircraft would be impounded for such an oubli, unless the pilot argued that he did not need to have it on board.

Sorry but I could not disagree more. Electrical malfunctions are a perfect exampel where one should consult the POH before doing anything, even in simple aircraft. The C172S POH for example devotes 2 pages in the amplified emergency procedures sections to electric malfunctions. If you bumbling along in cruise and you think you may an electrical problem I would suggest the first thing you should do is the emerg checklist and then consult the POH amplified procedures section to get the whole picture. Sure there are lots of situations when you have more important things to do then read the POH, but time and circumstances permitting the last line on every emerg checklsit should be a POH page reference. I can see now why the Carb Heat thread on the instructors forum is full of such silliness. It is obvious most posters have no idea what their aircraft POH actually says, so I wonder if this is a result of a culture where the priority is keeping the POH safe and prisitine on the shelf, not what it should be .....the well thumbed go to reference for how to operate the aircraft.....

I have a certain sympathy for that. However, the devil is in the detail.

In the case of our 1966 Twin Comanche, I have two documents that tell me how to operate the aircraft. One is a 1960s "Owners Manual" provided by Piper, the other a much more recent POH developed by the International Comanche Society. Both are excellent reads, cover to cover.

By contrast, the official Aircraft Flight Manual, which I am (or perhaps, am not?!) required to carry, contains the almost suicidal take-off technique developed to cope with a paper increase in Vmca, tells me in 20-odd pages how to construct an engine out flight path that clears obstacles that don't exist, declares a nominal speed for flight over water that featured in a regulation that disappeared 20 years ago, and reminds me, quite succinctly I must confess, that the minimum crew for the operation of the aircraft is one pilot. It is, to all intents and purposes, an obscure technical document!

“Electrical malfunctions are a perfect exampel where one should consult the POH before doing anything, even in simple aircraft.”

I would hope that pilots would have made themselves aware of its contents so they could deal with the problem without the book. My POH (is so much as it exists) contains nothing on the electrical system at all, but flying without an idea of the issues would be foolhardy, as would trying to fly VFR using see and avoid with your head in a book!

Rod1

I think we're possibly in violent agreement. Where we perhaps disagree are the "circumstances". Simply that in the realms of "Aviate, Navigate, Communicate" in an aircraft which is not behaving itself, thumbing through to find Chapter 4, Subsection 6, Paragraph 3 after you have already secured the aircraft from it's failure by carrying out the appropriate QRH drill is going to cause some detriment to the "Aviate" part.

I fully agree with your "circumstances permitting" but I put forward the notion that while an experienced PPL will likely have the judgement to determine whether the circumstances do in fact permit some serious eyes down, an inexperienced PPL or a student may not. If the manual is on board, there may be a point where it can be a useful reference but in the open FIR, IMHO keeping a good lookout and distraction management should be a greater priority than trying to find an obscure paragraph in the POH after you've completed the QRH drill.

In addition to the foregoing, I will add that for many aircraft I know of (most Cessnas for certain), the Type Certificate Data Sheet specifies the flight manual as required equipment (meaning thou shalt not fly without it aboard). It does not offer that you may carry a copy.

Therefore, without a flight manual, the aircraft does not meet it's type design, and is therefore not legally airworthy.

A multi engined turbine aircraft with which I am associated, is operated by it's operator with substitute documents for the flight manual (hance I could not find the actual flight manual aboard, when it should have been there). The result was that the substitute document omitted an item on the after landing checklist, and thousands of dollars of damage was done to the aircraft because it was left on errantly. Had the pilots refered to the actual flight manual, it would have been turned off.

Flight manual has to be aboard....