Difference between Pre-Flight Inspection
& Pre-Flight Maintenance
‘Pre-flight Inspection’ means the inspection carried out before flight to ensure that the aircraft is fit for the intended flight.
So before each intended flight
which the flight can be for any purpose, the responsible person is the Pilot,
so the Pilot is the person who ensures that the aircraft is fit for the flight.
Therefore Pilot carryout the Pre-flight Inspection.
The required training for The pilot is given during the aircraft type training. Also in the AFM set the requirements
for the Pre-Flight Inspection.
‘Maintenance’ means any one or combination of overhaul, repair, inspection, replacement, modification or defect rectification of an aircraft or component, with the exception of pre-flight inspection.
So the Pre-flight Inspection is
not a maintenance task. So Pre-flight Inspection doesn’t need the CRS.
Then Pre-flight Inspection is an
operational requirement. And should be done by the PIC.
Ref Part-M, Subpart-B ACCOUNTABILITY,
M.A. 201 RESPONSIBILITIES (d) The pilot-in-command or, in the case of
commercial air transport, the operator shall be responsible for the satisfactory accomplishment of the pre-flight inspection. This inspection must
be carried out by the pilot or another qualified person but need not be carried
out by an approved maintenance organisation or by IS-66 certifying staff.
The Pilot is already qualified to
carry out the Pre-flight Inspection. And also note it not need to be carried
out by an AMO or by IS-66 Certifying Staff, ie because it does not need a CRS.
So any person, even IS-66
Certifying Staff who required to carry out the Pre-flight Inspection should be
qualified for the Pre-flight Inspection.
Now who will define the
qualification criteria?
It is the CAMO.
Ref Part-M, Subpart-C CONTINUING
AIRWORTHINESS, M.A. 301 CONTINUING AIRWORTHINESS TASKS (1) The accomplishment
of Pre-flight Inspection.
So the first Continuing AW task
is the accomplishment of the Pre-flight Inspection.
But shall they carryout the Pre-flight
Inspection?
No, refer sentence above in the
regulation “The aircraft continuing airworthiness and the serviceability of
both operational and emergency equipment shall be ensured by”.
So the CAMO’s responsibility is
to will ensure that the Pre-flight Inspection is carried out. CAMO has to set
Criteria for the Pre-flight Inspection.
Referring AMC M.A.301 -1
Continuing Airworthiness Tasks, the guidelines are given. Also under (3) it stated that in the case of
CAT, an operator should publish guidance to maintenance and flight personnel
and any other personnel performing Pre-flight Inspection tasks, as appropriate,
defining responsibilities for these actions and, where tasks are contracted to
other organisations, how their accomplishment is subject to the quality system
of M.A. 712
Where should it mentioned;
Ie the CAME. The training
standard for personnel performing the Pre-flight Inspection should be described
in the operator’s continuing airworthiness management exposition.
So if it somebody else other than
the pilot, the qualifications, responsibilities and training standard should be
mentioned in the CAME.
So how the recording of the carrying
out of the Pre-flight Inspection?
Referring to AMC M.A.306 (A) OPERATORS
TECHNICAL LOG SYSTEM, the Tech Log should need to have 5 Sections. In Section
3, it is required to have the Pre-flight Inspection signature.
When CAMO approving the Tech Log,
it should be in align to these requirements stated in AMC M.A.306 (A).
So this is the Pre-flight Inspection.
Now misunderstanding again, that there is another Pre-flight in Part-M. I.e. Pre-flight Maintenance tasks.
Under Part-M, APPENDIX I TO AMC
M.A. 302 Content of the Maintenance Programme, 1.1.9 Details of Pre-flight Maintenance
tasks that are accomplished by the maintenance staff.
So it is a maintenance task which
has its interval in every pre-flight. This must be in the AMP and must be carried
out by a certifying staff and need a CRS since this is a maintenance task. So
this comes under Part-145.
These requirements can be from an ADs, SBs and reliability programme.
Now the qualification
Requirements for the Pre-flight Maintenance tasks.
If a Pilot needs to carry
out the Pre-flight Maintenance tasks ref 145.A.30 PERSONNEL REQUIREMENTS (J)
(3) For a repetitive pre-flight airworthiness directive which specifically
states that the flight crew may carry out such airworthiness directive, the
organisation may issue a limited certification authorisation to the aircraft
commander and/or the flight engineer on the basis of the flight crew licence
held. However, the organisation shall ensure that sufficient practical training
has been carried out to ensure that such aircraft commander or flight engineer
can accomplish the airworthiness directive to the required standard.
Also, Part-145 should
issue an authorization for the Pilot. Refer AMC 145.A.30 (j)(4) PERSONNEL
REQUIREMENTS, Limited Certification Authorization.
But the Pilot cannot do
any maintenance tasks, the pilot only can do maintenance tasks what the maintenance
data of that maintenance tasks specify that these tasks can be done by the pilot
or flight crew.
It is not them to decide
as a Part-145, it is the maintenance data will decide.
This is Pre-flight Maintenance tasks.
Nice article explains most of the gray areas. So whats the Daily Inspection? And is it mandatory?
ReplyDeleteDaily Inspection is for the maintenance tasks. And yes it is mandatory by the manufacturers' data.
ReplyDelete