Opinion: Understanding European Union Ramp Inspections

Europeans love rules. In fact, the European Union Aviation Safety Agency (EASA) has said that “rules and regulations are the core of the European Union [EU] civil aviation system.” So, naturally, they have a robust system to ensure that aviators are following their equally robust set of rules. That system is laid out in the Ramp Inspection Program.

The EU Ramp Inspection Program includes inspection of member state aircraft through SACA—Safety Assessment of Community Aircraft—and foreign aircraft through Safety Assessment of Foreign Aircraft (SAFA).

Many operators have heard of the 53-item Ramp Inspection Manual. However, inspectors examine each of the 53 items for several elements, all of which are outlined in EASA’s 300-page Inspection Instructions and Pre-Described Findings document. Inspection standards are set by:

1. The International Civil Aviation Organization international standards for aircraft used by third-country operators;

2. The relevant EU requirements for aircraft oversight of another member state;

3. Manufacturers’ standards when checking the technical condition of the aircraft; and

4. Published national standards (e.g. Aeronautical Information Publications, or AIP).

EASA uses these documents to set the ground rules for an inspection, but civil aviation authorities (CAA) typically employ the inspectors conducting the inspection. So, EASA is not actually performing ramp inspections. EASA collects and aggregates the reports, creating a key benefit in today’s world: data.

Data allows participating CAAs to track non-compliance and, more importantly, safety risks.

Operators can expect to encounter ramp inspections in EU member states, plus Albania, Armenia, Australia, Azerbaijan, Bosnia and Herzegovina, Brazil, Canada, Georgia, Iceland, Israel, Republic of Moldova, Monaco, Montenegro, Morocco, Norway, Qatar, Serbia, Singapore, Slovak Republic, Switzerland, the Republic of North Macedonia, Turkey, Ukraine, United Arab Emirates and the UK. In all, these agencies conduct more than 10,000 inspections per year, roughly 15% of which concern general aviation aircraft. At one time, the FAA was exploring participating in this program. Participation would provide access to the inspection data. However, FAA would also be expected to contribute, which would require inspecting foreign air carriers visiting the U.S.

Inspection Time

If you find yourself as the subject of one of these inspections, keep in mind:

■ Inspectors will not jeopardize crew duty times;

■ Inspectors will avoid unreasonably delaying the aircraft; and

■ Inspectors should not interfere with crew boarding and disembarking.

Inspectors know that they cannot delay a departure, so expect to receive an inspection upon arrival. After a long trip across the Atlantic, an inspection, or any delay, is likely the last thing the crew wants before proceeding to the hotel for rest. Nonetheless, it is important to remain cordial.

After the inspection, the inspector will debrief the pilot in command (PIC). Hopefully, the inspection will not turn up anything. However, if it does, findings will be categorized as 1 (minor), 2 (significant) or 3 (major).

Category 1 findings only have a minor influence on safety, so the inspector will inform the PIC and send a notification through the ramp inspection tool. No follow-up is required. Category 2 or 3 findings result in the inspector sending written notification, requesting follow-up on corrective actions and notifying the FAA. On some occasions, that may mean follow-up actions from the FAA to ensure the operator has rectified the finding.

Findings may result in verbal warning or fines—and, in extreme cases, a Category 3 major finding could cause an inspector to ground the aircraft. Inspectors may also ground an aircraft if the inspector believes the PIC will not take steps to correct the finding.

In addition to inspecting the aircraft and flight documents, inspectors have the authority to conduct random drug and alcohol tests on pilots. Recognizing this can be sensitive, even if there was no reason for suspicion of nefarious behavior, the inspector’s guidance suggests conducting the test out of view of passengers and other crew. Initial cooperation is the best course of action. Know your rights and the protocols. Refusal to comply will be treated as testing positive. If the test result comes up positive, the inspector will conduct a second test for verification.

Common Findings

EASA publishes the most common findings. Expect inspectors to be particularly alert for these items.

A23 – Defect notification and rectification. If you have any deferrals, be sure they are properly documented and within prescribed time limits. Many findings under this item concerned defects that were not identified or not reported.

A13 – Flight preparation. Under this inspection item, inspectors check the flight plan, the performance and fuel calculation, and selection of alternate destinations. NBAA just published a standardized International Flight Plan Format Guide intended to help operators comply with EASA flight preparation expectations.

B01 – General internal condition. The cabin crew must be able to perform duties without hindrance. The findings mainly revealed the poor condition of the cabin and improperly stowed luggage or catering equipment.

A07 – Minimum Equipment List. Minimum equipment lists (MEL) are optional in the U.S. They are required in Europe.

Further, EASA requires a fully customized MEL, while the FAA permits Part 91 operators to use a master minimum equipment list (MMEL) as an MEL. For Part 91 operations, the FAA authorizes use of an MMEL as an MEL through LOA D095 and authorizes use of a fully customized MEL through LOA D195. The FAA included a sample attestation letter in AC 91-67A. If the operator completes and submits the attestation letter, indicating the information in the application conforms to the contents of AC 91-67A, the FAA can expedite the review of the operator’s application.

If you arrive at your destination to find inspectors waiting, be polite, cooperate and be patient with the process. Inspectors have always viewed “compliance attitude” as a key factor.

Author’s note: Thanks to Brian Koester, formerly of NBAA, for his help in writing this column. He is now an aviation compliance and operations analyst at Jetlaw.