Airworthiness Review Signatory – An Explanation
In this week’s blog, I thought that I would take the opportunity to answer a direct question posed last during a discussion on another forum, “never heard of an airworthiness revue signatory before in my 40 years of aircraft ownership. What do you do?” After deciding not to make frivolous comment about not dressing-up! I thought this was a worrying statement given Part M and associated requirements have been in place for 2 years, give or take a few days.
What Qualifications should I have?
I think to answer that question fully, I need to outline the background and experiences that are required by an Airworthiness Review Signatory (ARS), an ARS should:
- Have at least 5 years in a continuing airworthiness management environment, such as:
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- Technical Records;
- Planning;
- Development Engineering, and;
- Be an appropriately type rated licensed engineer, or a graduate engineer, or 5 years experience over and above that required above, ie 10 years in the field, and;
- Have a formally recognised training, and;
- Hold a position of responsibility with the organisation.
The above limits are applicable to those supportinmg comercial air transport of any weight, and non comercial air transport aircraft above 2730kg MTOM; for aircraft below that weight operated privately the experience requirements canbe reduced to 3 years.
All ARSs are interviewed and approved by the CAA, they must hold an EASA Form 4, and be able to demonstrate currency in their experience of continuing airworthiness management. They will have carried out an Airworthiness Review under guidance, either from the CAA or internally. It is essential the ARS is not involved in the day-to-day airworthiness management tasks on the supported fleet. They cannot decide the application of individual directives and bulletins across the fleet.
What do I do?
The Airworthiness Review is a sample check of the records, and follows a simple check list, which when completed forms part of the aircraft history. So what do I sample?
- Is the aircraft and engine utilisation accurate;
- Are all deferred defects, correctly deferred;
- I look at the AD/SB status, picking a number of the entries, both applicable and non-applicable to confirm the status of the entries;
- I would review AMP against the MPD or Chap 4/5 for the aircraft against the aircraft history, has the maintenance required been carried out when it was due?
- I review the aircraft documents and log-cards, selecting a number of serialised components to confirm what the records say is fitted is actually fitted;
- Have all the mods and repairs been approved by a correctly approved design organisation;
- The aircraft configuration and weight match the Type Certificate.
The aircraft survey, do all the mandatory markings match the AFM and other approved documentation requirements, do the components fitted match the records. If all the of the above are found to be correct, I will raise and sign the ARC for an aircraft not operated for commercial gain, acting on behalf of an AOC holder I will submit a recommendation to the CAA for the issuance of an ARC; if however, there are discrepancies, I will not sign that ARC and depending on the nature of the discrepancy, the aircraft maybe grounded until it is resolved. On private aircraft it is usually un-approved modifications that are the issue.
An organisation approved to raise and sign the ARC can also import aircraft into this country, subject of another article.
