International Ops 2018

Flight Service Bureau | OPSGROUP

Tag: MMEL

That MMEL thing: here’s an update

The FAA is set to issue new guidance to provide a resolution to the long-running MMEL vs MEL debacle. However, it may not be the one we were expecting!

Last year, ramp checks on some US aircraft in France highlighted an important issue – EASA and the FAA have different interpretations of the ICAO standards regarding deferring aircraft discrepancies.

In the US, with FAA authorization operators can use a master minimum equipment list (MMEL) to defer repairing certain equipment. But in Europe, MMEL cannot be used in lieu of an MEL specific to each aircraft or fleet.

The European Aviation Safety Agency (EASA) began requiring all aircraft transiting European airspace to have an approved Minimum Equipment List (MEL) for each, individual aircraft. An MEL that references the MMEL was not acceptable.

This was a pain for US operators, as to get an individual MEL approved under the Letter of Authorisation (LOA) from the FAA takes time – but by not doing so, they ran the risk of failing a ramp check in a European country.

At the start of 2018, we understood that the FAA had reached an agreement with EASA: the FAA would start requiring international operators to obtain new D195 LOA’s, and in return EASA would halt any findings for a period of 12 months to allow for these new LOA’s to be issued.

But now we understand the FAA have decided that making operators get new D195 LOA’s will be far too much work for everyone involved!

Instead, they intend to just continue to issue the D095 approvals – but they will more vigorously validate the required components (such as the Preamble and M&O procedures).

This certainly appears to present a reversal of the previous commitment to EASA, who may very well not accept these LOA’s. If that happens, then the approval won’t be valid over in Europe – meaning ramp checks of N-reg aircraft in European countries will once again throw up the old MMEL finding, just like before.

We expect the FAA to officially issue this updated guidance to inspectors in the very near future, to be followed by a FAA InFo Letter to Part 91 Operators. The NBAA have said they will issue a bulletin to share the guidance as soon as it is released.

How to prepare for a ramp check in Europe?

We wrote a 2017 article all about how to make a ramp check painless.

We have also updated the FSB SAFA Ramp Checklist. Download it here.

Keep a copy with you and run through it before you head towards the EU.

 

 

Further reading

European Ramp Checks – most popular questions from inspectors

Of late, the level of interest in OpsGroup for European Ramp Checks has been very high.  There has been a lot to think about. First, we discovered in March that French inspectors had started recording a finding for operators that were using the Manufacturer MEL instead of a customized one, and it turned out that across EASA-land inspectors were raising the same issue. There is an update on that below.

One of our members posted a great list of the most popular findings/issues raised by EASA Inspectors in the last 12 months, together with the skinny on “how to fix these, so you don’t get a finding”.

So, first let’s look at the Top 3 Categories, with the subset questions, and then an update on the D095 MMEL/MEL issue.

Popular European Ramp Check Items

Visiting and locally based aircraft may be subjected to ramp inspections as part of a States’ Safety Programme. The EU Ramp Inspection Programme (EU RIP) is one such inspection regime which currently has 48 participating states. The EU Ramp Inspectors review findings and use this intelligence as a basis for prioritising areas to inspect during a ramp check.

The most frequent findings and observations raised since January 2016 follow. This information can be used to help avoid similar findings being raised during future ramp inspections on your aircraft.

Most Frequent Findings

The main 3 categories of findings, relate to: Minimum Equipment Lists, Flight Preparation and Manuals.

1. Under the category of Minimum Equipment List, the finding is.
• MEL not fully customised.

2. Under the category of Flight Preparation, the main findings are:
• PBN Codes recorded on the flight plan which the operator did not have operational approval for
• Use of alternates which were not appropriate for the aircraft type; and
Use of alternate airports which were closed

3. Under the category of Manuals, the main finding is.
• AFM was not at the latest revision.

 

Simple Steps to Avoid Similar Findings

1.    Review your MEL, especially amendments made to the MEL after the initial approval, and ensure it is fully customised:
•    Where the MMEL and/or TC holders source O&M procedures require the operator to develop ‘Alternate Procedures’ or ’Required Distribution’ etc. these must be specified in the operators MEL and/or O&M procedure;

 

Full report in your OpsGroup Dashboard, including the standard ramp checklist PDF:

Opsgroup Dashboard login Join OPSGROUP for access

To get the full report and checklist – there are two options:

  1. OPSGROUP Members, login to the Dashboard and find it under “Publications > Notes to Members”. All FSB content like this is included in your membership, or 
  2. Join OPSGROUP with an individual, team, or department/airline plan, and get it free on joining (along with a whole bunch of other stuff), or
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