Has the FAA done a deal with EASA to do ramp checks on N-regs?

alioth wrote:

that’s good there’s no specification

I wouldn’t say that is true. EASA specifies this within some AMC and ICAO has a recommendation about this. You don’t need actual journey log. You could have the required information as part of a plog and simply keep the old ones as long as required. They could even be scanned or photographed. As far as non-commercial non-complex operations go and AFAIK.

Yup. Part-NCO says you can use PLOGs instead of a journey log. But as you say, you must save them all. Just showing the last one at a check won’t do.

Salient points on conduct of check below, it’s the same legislation for small piston aircraft. It stipulates in the final paragraph I pasted that it’s a good idea if the Operator’s representative is in attendance. Good advice I think and another good reason to email your docs beforehand to them, especially if you haven’t been there before, or if it’s notorious for ramp checks. I’ve tried it and it does work. Google SAFA ramp inspection checklist for the rest of the doc. Also, the inspector / policeman when asked has to provide by law proof of qualification and also currency to conduct the check (from memory 12 documented checks a year and also proof of recurrency)

“Inspectors must show tact and diplomacy when performing a SAFA Ramp Inspection. Any unnecessary contact with passengers should be avoided; however, this may be justified so as to be able to inspect certain elements in the cabin, such as:

properstowageofcabinbaggageundertheseat,

overweightinoverheadluggagebins,

baggage in front of emergency exit,

infants/children over the minimum age determined by the State of oversight

should have their own seat,

passengersrepartitioninthecabin,comparedtotheloadsheetdata,

sufficient number of seats,

observing the boarding process during normal operations, during refuelling in

progress.

f) Departure delay of an aircraft should be avoided. However, when an inspector discovers an issue which may have a major effect on flight safety or requires further investigation to be clarified, a delay may be justified, for example:

thetyresappeartobewornbeyondthelimits(centralgroovenolongervisible), however reference must be made to the applicable AMM to determine the actual limit;

an oil leakage (e.g. 5 drops/minute) must be checked against the applicable AMM to determine the actual limit;

a flight crew member cannot produce his/her licence. Clarification must be sought from the operator to confirm that the flight crew member has a valid licence by requesting, for instance, a copy of the licence to be sent to the inspectors for verification.

Note: the limitations quoted in the examples are here for illustration purposes and should not be applied during a ramp inspection, knowing that the defects raised must be studied in

SAFA Coordination Section Page 9 of 217 © European Aviation Safety Agency, 2012 V 2.0

the limitations enacted in the applicable documentation of the inspected airline

g) A certain amount of inconvenience to flight and cabin crews, handling agents and other personnel involved in ground handling activities may arise, but inspectors must do everything possible to reduce hindrance to the minimum, for example:

they should try to be as precise and complete as possible when asking for A/C documents from flight crew. This should result in a minimum of discussion time allowing the flight crew to deal with their primary task of flight preparation;

they should ask the senior cabin crew member to dedicate one crew member to assist them with the inspection tasks;

they should debrief the commander of the aircraft after the inspection task is completed;

they should inform cargo loading staff of possible hindrance due to inspection task in cargo compartment;

when carrying out inspections on the flight deck, the flight crew should be allowed to give priority to staff directly involved in the flight preparation (e.g. fuel master, load-planning agent, handling agent pax. info, etc.).

h) SAFA inspectors should try to perform all of the SAFA checklist items. When circumstances prevent this (time, manpower, etc.), try to inspect those elements which, according to inspectors’ preparation and experience, are likely to be more safety critical: this is depending on the particularities of the inspected flight. Elements to be taken into account are:

In general, certain elements are less safety critical. E.g. a noise certificate has far less impact on safety than incorrectly completed Mass & Balance documentation (or incorrect calculation) and should therefore be given a lower priority.

The difference in the aircraft configuration. Whereas for a cargo configuration the securing of the cargo and the segregation of the dangerous goods is important, for a passenger configuration refuelling with passengers on board could have a higher priority.

Previous SAFA results. If serious and/or recurrent findings were raised during previous inspections on e.g. the MEL, this might become more important than the flight preparation on which previously no non-compliances were found.

Type and age of the aircraft. Some aircraft types are known to have issues with e.g. leakages or missing screws. Age of the aircraft could be of influence as well.

i) Nothing should be done in the course of a SAFA Ramp Inspection that hinders the crew/passengers that could just as well be inspected on another aircraft of the same operator without causing delay/hindrance.

j) Whenever possible, it is advised to contact the operator’s representative at the airport so that he/she can be present during the SAFA Ramp Inspection. Experience shows that the operator’s representative may be helpful in providing support especially in facilitating communication with the crew or operator home base.

Ramp Inspector currency and training,

“A. RECURRENT TRAINING

Once qualified, ramp inspectors shall undergo recurrent training in order to be kept up to date.

A competent authority should ensure that all ramp inspectors undergo ad-hoc recurrent training whenever it would be deemed necessary due to significant changes in the EC SAFA Programme’s structure and procedures, or regularly, at least once every three years after being qualified as ramp inspectors.

EASA will indicate in the SAFA Training Bulletin as referred to in paragraph 40 when an ad-hoc recurrent training would be deemed necessary.

Recurrent training shall be delivered by the competent authority or by a SAFA training organisation.

The scope of the recurrent theoretical training is to refresh the knowledge of the qualified SAFA inspectors:

The recurrent training should cover at least the following elements:

1. New regulatory and procedural developments:

a. b.

New/amended standards New/amended SAFA Guidance Material

EASA SAFA Guidance Material Annex to ED Decision 2008/001/S

c. Changes in the categorisation of findings

d. New/upgraded IT tools

New technology and/or operational practices

Articulation with other European processes (Black List, authorisation

of 3rd country operators)

Standardisation and harmonisation issues:

Issues of general interest identified by the SAFA standardisation visits;

Issues identified by periodic quality reviews conducted by EASA;

Best practices.

The duration of the recurrent theoretical training should be adequate to the extent of the new information to be provided. The typical duration of recurrent training should be not less than 1 training day and the format of the course should encourage the exchange of experience among the participants.

In order to enhance the effectiveness of the recurrent SAFA training EASA will publish at least annually a SAFA Training Bulletin comprising relevant, updated information to be incorporated in the recurrent training.

Appropriate records should be kept by the competent authority attesting that all ramp inspectors have successfully completed the recurrent training.

B. RECENCY REQUIREMENTS

The minimum number of inspections required for ramp inspectors to maintain their qualification should be not less than 12 SAFA ramp inspections during any 12 months period after initial qualification, preferably evenly spread during such intervals.

As a transitory measure the minimum number of SAFA ramp inspections may be reduced to 8 for the 12 months periods ending in 2009 and reduced to 10 for the periods ending in 2010.
The minimum number of 8 inspections may also be used for those inspectors who are considered to be qualified in accordance with paragraph 2.6.1 of the Annex to the Commission Directive 2008/49/EC.

This number could be reduced with the number of inspections on aircraft operated by domestic operators if the inspector is also a qualified flight operations, ramp or airworthiness inspector of a competent authority and is regularly engaged in the oversight of such operators.

If a SAFA inspector lost his/her qualification as a result of failure to reach the minimum number of inspections mentioned in paragraph 42 above he/she may be re-qualified by the competent authority by performing at least 2 inspections under the supervision of a senior inspector; the time between these two inspections should be not more than 2 months.

If a SAFA inspector lost his/her qualification because he/she has not been engaged in performing inspections on aircraft for more than 12 months he/she may be re-qualified by the competent authority only after successfully completing OJT as prescribed in paragraphs 16-27 and any recurrent training required.

If a SAFA inspector lost his/her qualification because he/she has not been engaged in performing inspections on aircraft for more than 36 months he/she should be fully re-qualified by successfully completing initial theoretical, practical and on the job training. "

Airborne_Again wrote:

But as you say, you must save them all. Just showing the last one at a check won’t do.

…and it says so where?

Cobalt wrote:

…and it says so where?

Well, single plog is equivalent to a single entry which hardly constitutes a log unless it’s the first flight.

NCO.GEN.150 Journey log

Particulars of the aircraft, its crew and each journey shall be retained for each flight, or series of flights, in the form of a journey log, or equivalent.

Notice the “each”. The question is how long you should keep it. When you can start throwing old plogs out. For other ops they specify three months I think. OTOH as long as an electronic copy is enough it doesn’t matter that much.

PS: @Airborne_Again You can use any equivalent means, plog is just an example. The important thing is it contains what they want, there is just no need for a dedicated “book”.

Peter wrote:

Otherwise, why did they close the Frankfurt office? It was big and reportedly busy.

My guess would be that FAA felt the money could be spent more productively elsewhere, given that EASA is attempting to extend the European role in world wide air commerce, and thereby providing the potential (realized or not) for a locally funded partner. Basically an extension of broader US policy / pullout from the region, and not anything hinged on any particular issue like EASA ramp checks of FAA light aircraft under treaty.

Silvaire wrote:

My thought on that is that FAA does not do “quiet deals” with foreign government

And surely there would not be any need to do so? At a French airfield, the local gendarmarie will have every right to check that foreign registered aircraft are applying with the applicable regulations, and it wouldn’t surprise me at all for certain common foreign registers, the officers make themselves aware of the common requirements for flying an aircraft of that registry (after all, all the FAA regs are very easy to find and digest online – I wish EASA did the same!)

Perhaps some disambiguation is in order here.

There are Police controls (including Customs & Imigration) and there are “ramp checks” .

Ramp checks are those that are performed by FAA Safety Inspectors.

The two examples in the OP are clearly Police Controls.

That said, I read somewhere last year an article that explained that the OSAC agents could & would be performing ramp checks which they have not done before.