Maintenance and Manufacturing Staff Instructions (MSI) No. 6

Subject:	Number:	MSI 6
Ramp Surveillance	Revision No:	1
	Number of Pages:
File No: AARP-5009-3-6	Issue Date:	January 18, 1999

1. Purpose

1.1 These procedures outline the criteria for conducting ramp surveillance.

2. Background

2.1 As airport activity increases, the requirement for ramp surveillance by Civil Aviation Maintenance Inspectors also increases. The scope of surveillance ranges from observation and comparison of a single maintenance activity for conformance to standards, to the inspection of an entire aircraft and the verification of its compliance with applicable requirements, standards and procedures.

3. Definitions

3.1 For the purposes of this MSI, "ramp surveillance" means the observation and analysis of ramp and line maintenance activities for overall quality, compliance with specified methods, techniques and practices, competency of personnel and compliance with regulatory requirements.

4. Need for tact

4.1 Tact and diplomacy are essential when conducting surveillance of air operators, both domestic and foreign. Inspectors must advise the flight crew that their objective is to determine that the aircraft being inspected complies with the Canadian Aviation Regulations for Canadian registered aircraft or International Standards for Airworthiness of Aircraft, Annex 8 to the Convention on International Civil Aviation for foreign aircraft.

4.2 Inspectors should obtain flight crew authorization to board the aircraft. If the flight crew is unavailable, authorization must be obtained from senior cabin staff, the airline station manager, the local maintenance manager or other responsible airline official.

4.3 If a safety related item is identified, the flight crew and/or the maintenance representative of the aircraft shall be notified, and a determination made as to the appropriate course of action.

4.4 Where an aircraft has sustained damage or is otherwise unairworthy, the inspector should confirm that the company has taken appropriate action to rectify the problem.  If the company has declined to carry out the necessary repairs, the aircraft shall be detained. The Director, Maintenance and Manufacturing (AARP) and, if the aircraft is foreign registered, the Chief of Foreign Inspection (AARXH), shall be notified of the detention as soon as possible. The Chief of Foreign Inspection will immediately notify the applicable civil aviation authority of the country of registry.

5. Part One - Domestic Operators

5.1 Air Operator Surveillance

1. Surveillance activities normally consist of visits to maintenance bases or sub-bases used by the air operator, and also serve to gather and maintain information regarding equipment and inspection difficulties which may not be formally reported. During surveillance, emphasis should be placed on any known existing weaknesses of the air operator. Obviously deficiencies, affecting the safety of the aircraft, will require immediate action. Noted deficiencies shall be brought to the attention of the appropriate party, and the Principal Maintenance Inspector (PMI).
2. Records must be maintained and should include activities carried out and any significant observations made. Such records are useful during future visits. One copy will be placed on the company file, and where applicable, one on the aircraft file. Findings requiring action should be forwarded to the Office of Primary Interest (OPI).

5.2  Inter-regional Coordination

1. Where an air operator's scheduled routes include stops in more than one Transport Canada region, the region where the operator is based is responsible for requesting surveillance assistance from another region.
2. On occasion, inspectors will require immediate access to supervisory or specialist personnel. Since the dispatch of aircraft could be affected, provisions should be made for timely assistance. Procedures for an effective communications system should be established.

5.3  Domestic Surveillance - General

1. As a general rule, two inspectors should be assigned as a surveillance team. Both should have relevant aircraft training and/or experience, and one should have a substantial avionics background. Both Inspectors must be conversant with the regulations relating to the transportation of dangerous goods and live cargo.
2. Ramp surveillance should be conducted on both a planned and random basis, and should take into account the 24 hour day, 7 day week, nature of the industry. Air Operators having overnight maintenance bases should be randomly inspected at night, as well as during the busy early morning and early evening operational hours.

5.4  Domestic Procedures - General

1. When conducting surveillance, the Inspectors should identify themselves to the owner or operator of the aircraft or facility, and announce their intention to inspect the aircraft, facility, records, etc. If necessary, the appropriate Ministerial Delegation of Authority should be quoted; e.g., paragraph 8.7(1) of the Aeronautics Act. Inspectors should not enter the aircraft without authorization of the owner or his representative. If entry is refused, the owner or operator should be advised of the offence of willful obstruction (paragraph 7.3(1)(d) of the Aeronautics Act).
2. Should the Inspector again be refused entry, and he believes on reasonable grounds that the aircraft is unsafe or is likely to be operated in an unsafe manner, he should detain the aircraft pursuant to section 8.7(1)(d) of the Aeronautics Act; and issue form 26-0365 Notice of Detention of Aircraft. If necessary the local RCMP office should be contacted for assistance as required.
3. Surveillance must be conducted with a minimum of interruption to maintenance and or passenger handling. Inspectors will normally direct their discussions to maintenance personnel, flight engineers and company Inspectors. Caution must be exercised when addressing complaints or requests for action to the appropriate supervisor on duty.

5.5   Aircraft Inspection

1. The items noted in Appendix A, Aircraft Surveillance Report should be considered (as applicable) as a minimum when conducting surveillance on domestic air operators, and should not be considered as an all encompassing list.

5.6 Line Maintenance

During surveillance of line maintenance activities the following should be taken into consideration:

1. Handling of hazardous materials.
2. Passenger, maintenance and crew safety.
3. Parking and dispatching of aircraft.
4. Adequacy of ramp precautions and line maintenance functions.
5. Quality of inspection documentation and related corrective actio entries are reports.
6. Control of inspection documentation.
7. Availability and utilization of standards and instructions for the work being performed.
8. Availability of equipment for the maintenance conducted.
9. Control of deferred maintenance items.
10. Production and quality control procedures.
11. Observation of engine maintenance where/when applicable.
12. Use of calibrated test equipment.
13. Winter deicing practices.

5.7 Satisfactory Inspection
Where an aircraft is found to be satisfactory, an Aircraft Inspection Report, Form 24-0008 should be placed on the regional 5008-file and surveillance files, where applicable.

5.8 Unsatisfactory Inspection
Where deficiencies require corrective action, the aircraft operator should be notified by issue of a Letter of Notification, Form 24-0019. Copies should be placed on the 5008 and surveillance files, where applicable. Where the inspector has reason to believe that a notice of aircraft condition may not be sufficient to prevent the operation of an unairworthy aircraft, a Notice of Suspension Form 26-0370 shall be issued.

5.9 Contract maintenance
Ramp and line surveillance should also encompass work performed by contract agencies to ensure that the responsibilities of both parties are being met. The Air Operator's MCM or the AMO's MPM will outline the policies governing maintenance arrangements.

6.  Part Two - Foreign Air Operators

6.1  Direction

1. All personnel engaged in ramp surveillance of foreign air operators should follow the general guidelines given in this part.

6.2  Background - Role of Foreign Inspection Division

1. The reorganization of Civil Aviation within Transport Canada has resulted in the consolidation of Civil Aviation's maintenance, flight operations and cabin safety responsibilities pertaining to foreign air operators within the Foreign Inspection Division of Commercial and Business Aviation. The Foreign Inspection Division (AARXH) regulates all foreign commercial air operators operating in Canada.
2. The provision of foreign air operator safety regulation is achieved by processing and issuing Foreign Air Operator Certificates (FAOCs) pursuant to the requirements of CAR 701 and by managing a safety oversight program of all foreign air operators whether certificated or not, while they are operating in Canada or in Canadian airspace.

6.3  Risk Management

1. The Foreign Inspection Division is utilizing risk management principles as the most effective means to manage the oversight activities on foreign air operators in Canada.  These principles are applied during initial certification of the foreign air operator and also as a continuous activity, as long as the foreign air operator is a holder of a Canadian FAOC.
2. Ramp surveillance of foreign air operators, in conjunction with a systemic review of the corresponding reports (both satisfactory and unsatisfactory) generated by Transport Canada Inspectors, provide one of the risk indicators crucial to the effective risk management of the foreign air operators.

6.4  Maintenance of  Records

1. Regional airworthiness personnel who generate correspondence, reports etc. concerning foreign air operators shall ensure that a copy of the associated paperwork is forwarded to the Foreign Inspection Division, AARXH for filing action under the AARX 5258 file number.

6.5   Communications and Coordination

1. Each region shall identify a person within the region who will function as a single point of contact between the Foreign Inspection Division and the region. Normally, this person would be the Superintendent of the Air Carrier Section.  This is to ensure that regional supervisors are aware and approve of any tasking that is required to carry out the foreign registered aircraft surveillance. In addition, this will ensure that communication from the Foreign Inspection Division is directed to the appropriate inspectors who are performing foreign air operator surveillance within the region. 
2. In accordance with the regional policies, inspectors involved with the surveillance of foreign aircraft may initiate direct communication with the Foreign Inspection Division at any time on matters relating to foreign air operators.
3. The Foreign Inspection Division may be contacted at one of the following;

By Facsimile:
613-991-5188
Cellular:
613-720-958, or
Pager:
613-783-5789 

By Mail:

Foreign Inspection Division - AARXH
Commercial and Business Aviation
Place de Ville, Tower C,
330 Sparks St., 4th Floor,
Ottawa, K1A 0N8

6.6  Foreign Inspection Division personnel will be responsible for;

1. Receiving and processing all deficiencies pertaining to foreign air operators. This will include any necessary correspondence with the air operator and their Civil Aviation Authority;
2. Ensuring that any response from the operator pertaining to a regional inspector's finding is copied to the inspector who wrote the finding;
3. Requesting, when required, regional inspectors to conduct special ramp surveillance exercises with respect to foreign air operators; and
4. Personnally conducting special ramp surveillance exercises with respect to foreign air operators.

6.7  Levels of Surveillance

1. Routine - This type of surveillance will normally be conducted by regional airworthiness inspectors assigned to ramp surveillance duties and will involve the surveillance of a foreign air operator's aircraft;
2. Special - This type of surveillance is of a directed nature and will involve, as required, special inspections of a foreign air operator's aircraft, procedures, crew and facilities at the airport of operation.  This type of inspection will be initiated and normally be conducted by the Foreign Inspection Division.  When required, the Foreign Inspection Division may request, through the regional contact the assistance of regional inspectors to participate in such special inspections.

6.8  Aircraft Inspection

1. The items noted in Appendix A, Aircraft Surveillance Report should be considered (as applicable) as a minimum when conducting surveillance on foreign air operators, and should not be considered as an all encompassing list.

6.9  Standards

1. The following standards shall be considered during foreign air operator surveillance, as applicable:
    
   1. ICAO Convention;
   2. the Standards and Recommended Practices (SARPs) to the ICAO Convention; (commonly called Annexes);
   3. CAR 701; and
   4. NAFTA (Specialty Air Services).
       
2. In particular ICAO Annex 8, Airworthiness of Aircraft is to be followed.  The following extracts from Part II, paragraph 6, are provided for reference;
    
   1. Paragraph 6.1,  Any failure to maintain an aircraft in an airworthy condition as defined by the appropriate airworthiness requirements shall render the aircraft ineligible for operation until the aircraft is restored to an airworthy condition.
   2. Paragraph 6.2,  When an aircraft has sustained damage, the State of Registry shall judge whether the damage is of a nature such that the aircraft is no longer airworthy as defined by the appropriate airworthiness requirements.
   3. Paragraph 6.2.1,  If the damage is sustained or ascertained when the aircraft is in the territory of another Contracting State, the authorities of the other Contracting State shall be entitled to prevent the aircraft from resuming its flight on the condition that they shall advise the State of Registry immediately, communicating to it all details necessary to formulate the judgment referred to in the introductory standard of 6.2.
   4. Paragraph 6.2.2,  ".the State of Registry may, however, in exceptional circumstances, prescribe particular limiting conditions to the aircraft to fly without fare-paying passengers to an aerodrome at which it can be restored to an airworthy condition,.".
   5. Paragraph 6.2.3,  Where the State of Registry considers the damage sustained is of a nature such that the aircraft is still airworthy, the aircraft shall be allowed to resume its flight.

6.10  Reporting Requirements

1. Foreign registered aircraft surveillance activity should be recorded on a summary sheet, indicating the date; time; aircraft registration; aircraft make and model; name of the operator, and problems or observations and the name of the inspector conducting the inspections. The summaries should be forwarded to the Chief of Foreign Inspection Division (AARXH) monthly. A copy of this report will then be placed on the file of each applicable foreign air operator.  A sample copy of the summary sheet (Foreign Summery Sheet) is reproduced as Appendix B to this document. The reports will be utilized in conjunction with the copies of form 24-0018 (Letter of Notification, aircraft other than Canadian registered) to develop a foreign air carrier surveillance data.
    
2. Copies of the completed form 24-0018 shall also be forwarded to the attention of the Chief of Foreign Inspection Division as soon as being issued.

6.11  Deficiencies

1. Aircraft
   Generally, major and minor aircraft deficiencies may be raised during ramp surveillance.  With respect to foreign air carrier surveillance, TC is more concerned with major deficiencies.  Major deficiencies are those deficiencies which would, as determined by the inspector, affect the airworthiness of the aircraft.  This type of deficiency would be recorded on a form 24-0018 (Letter of Notification). The letter of notification is produced as a four part form.  The airworthiness inspector will give one copy to the air carrier or his agent, and will forward two copies of the letter to the the Foreign Inspection Division, AARXH.  The fourth copy may be retained within the region for regional records.  With respect to minor deficiencies and where it is considered necessary, the Inspector will verbally inform the operator and request that the deficiency be recorded in the journey log for subsequent corrective action.
2. Air Operator
   Routine ramp surveillance may reveal deficiencies which relate more to the air carrier's sub-base operation and turn around procedures (or lack thereof) at a particular airport.  With this type of deficiency the air operator may or may not be verbally informed of the deficiency by the inspector, but a report of the deficiency is required to be forwarded to the Foreign Inspection Division.

6.12  Follow-up action - (Foreign aircraft)

1. Where it becomes necessary to detain a foreign aircraft, the detention may be initiated by the inspector performing ramp surveillance in accordance with regional policies, but control of the resulting activity will be passed to the Chief of Foreign Inspection as soon as practicable. The Chief of Foreign Inspection will liaise with the involved civil aviation authority and the air carrier and will take further regulatory action as deemed necessary.

7. Forms

7.1 The following forms may be required when performing surveillance activities:

1. Aircraft Inspection Reports     24-0008
2. Letter of Notification (for aircraft other than Canadian registry)    24-0018
3. Letter of Notification     24-0019
4. Notice of Detention     26-0365
5. Notice of Suspension (Immediate threat to safety)  26-0367
6. Notice of Suspension (Failure to comply)    26-0370
7. Appendix  Aircraft Surveillance Report
8. Appendix B   Summary Sheet

8. RAMP Surveillance Formula

8.1  For resource planning purposes the following formula will be adopted:

(A x 0.5%) + (C x 10%) / 1314  =  the number of PYs required.

A = Total aircraft movements at carriers, group I-VI.  Only those airports in the applicable region have to be accounted for.

C = The number of commercial fleet in a particular region.

8.2  Data relating to foreign and domestic aircraft movements is available in Statistics Canada/Transport Canada publication TP577, Aircraft Movement Statistics.

9. Effective Date

9.1  This instruction comes into effect on February 18, 1999.

10. HQ Contact

10.1  The responsible officer indicated below may be contacted for information regarding this MSI:

R. Rose, AARPC
Aircraft Maintenance & Manufacturing Branch
E-mail: roserb@tc.gc.ca
Phone (613) 952-4375
Facsimile: (613) 952-3298

D.B. Sherritt
Director,
Maintenance and Manufacturing

Appendix B - Foreign Aircraft Summary Sheet

COPY TO:
SURVEILLANCE FILE   [       ] - _________
SUPERINTENDENT[   ]
AARXH   [   ]

Date	Time	Registration/Aircraft Tail Number	Aircraft make and Model	Name of Operator	PROBLEM / OBSERVATION		Type of Notice Issued
Inspector: Reporting Dates (From/To):