International Ops 2018

Flight Service Bureau | OPSGROUP

Tag: Ramp Check

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

EU SAFA ramp checks NOT on the rise – but are you ready for one?

In Short: SAFA ramp checks are continuing at the normal pace. Avoid the common mistakes of Fuel/Calc and Flight Routing (with SID/STAR), PRNAV/RNAV-1, incorrect flight plans and TCAS 7.1. If you do get a finding, expect to get a follow up ramp check the next few times you visit, to ensure compliance.

There have been more reports in Airport Spy recently which suggest there may be an increase in SAFA (Safety Assessment of Foreign Aircraft) ramp checks in Europe. So we reached out to a dozen SAFA offices around Europe to check if it was true.

Here’s what they told us:

  1. No, they’re not conducting significantly more ramp checks at the moment.
  2. No, they’re not looking more closely at certain items.
  3. Rather, the items checked during the SAFA/SACA inspections are based on a risk based approach and can differ from operator to operator (for example depending on findings raised during previous inspections). Meaning that operators who get ramp checked with findings will most likely get ramp checked again, to see if they’ve sorted out the problems!

Common Findings

But what are some common findings and the things to make sure you are doing right so you don’t get caught out?

  1. Fuel Calculation and Flight Routing: Alternates must be planned with a SID/STAR routing.

In many parts of the world it is common to plan DCT but not in many European countries. Non-compliance during a ramp inspection could lead to either a Cat 2 finding when sufficient fuel was taken into account such that the required fuel is above the minimum, or a Cat 3 finding when this was not the case.

  1. PRNAV/RNAV-1 capability.

Non-compliance constitutes a Cat 3 finding when landing at airports (such as EHAM/Amsterdam) that require it. The finding will also be reported to the aeronautical oversight department who can give fines for such violations.

  1. Filing incorrect flight plans – specifically saying you are 8.33 MHz equipped and PRNAV/RNAV-1 capable.

Again, this could lead to findings and fines beyond the SAFA programme. An easy one to miss.

  1. TCAS 7.1

The TCAS 7.1 requirement became mandatory in EU Airspace from 1st of December 2015 and became a worldwide standard under ICAO from 1st of January 2017.  One to also watch out for if operating to EU overseas territories in the Caribbean where this requirement has also been implemented and during ramp inspections is enforced the same way.

How to prepare for one?

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.

Back in 2016, EASA published new guidelines for inspectors to assess which aircraft should be prioritised for SAFA ramp checks in Europe and SAFA compliant states. For an overview of those guidelines, check out our article.

Have you been ramp checked recently? Let us know, by joining OpsFox! This is a community system, where every Pilot, Air Traffic Controller, Dispatcher, Handler, and CAA can add categorized reports, based on what they see and know at their home base or visited airport. Opsfox blurs the white noise and keeps only the relevant and current information at your fingertips, before you fly.

Extra Reading:

Expect breathalyzer during German Ramp checks

German authorities confirm they have been conducting random breathalyzer tests during ramp checks since as far back as Jan 2017, despite this not being part of the official EU SAFA ramp inspection guidelines.

In Dec 2016, following the accident of the Germanwings Flight 9525, EASA published a proposal to the European Commission to better support pilot mental fitness. One of their recommendations was to introduce random alcohol screening as a part of ramp checks within the EU.

Although that proposal has still not been adopted yet, local authorities in Germany say they can still perform these tests on the basis of German national law alone.

Have you had a recent ramp check anywhere with any surprise items not part of the standard checklist? Comment below…

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

Rules revised: SAFA Ramp Checks for ‘Suspect Aircraft’

01JUN: EASA have published new guidelines for inspectors to assess which aircraft should be prioritised for SAFA ramp checks in Europe and SAFA compliant states. ARO.RAMP.100(b) in the Part-ARO contains the updated list of aircraft that will be selected for priority checking:

(a) (when EASA receive) information regarding poor maintenance of, or obvious damage or defects to an aircraft;

(b) reports that an aircraft has performed abnormal manoeuvres that give rise to serious safety concerns in the airspace of a Member State;

(c) a previous ramp inspection that has revealed deficiencies indicating that the aircraft does not comply with the applicable requirements and where the competent authority suspects that these deficiencies have not been corrected;

(d) previous lists, referred to in ARO.RAMP.105, indicating that the operator or the State of the operator has been suspected of non-compliance;

(e) evidence that the State in which an aircraft is registered is not exercising proper safety oversight; or

(f) concerns about the operator of the aircraft that have arisen from occurrence reporting information and non-compliance recorded in a ramp inspection report on any other aircraft used by that operator;

(g) information received from EASA Third-Country Operator (TCO) monitoring activities;

(h) any relevant information collected pursuant to ARO.RAMP.110. (“whistleblowers”)

 

The revised Part-ARO, issued in May 2016, contains a large number of revisions and operators should take a close look at the changes.

For a general guide to SAFA Ramp Checks, have a look at our other article: Avoiding the Pain of a Ramp Check.

References:

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