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Old 06-20-2022, 10:49 PM
kearney kearney is offline
 
Join Date: Dec 2006
Location: Canmore, Alberta, Canada
Posts: 64
Default Inspection Protocol

Hi

For the benefit of builders who are new to inspections, the following is a brief description of how the inspection process should work.

MD-RA inspectors are tasked with issuing Special Certificates of Airworthiness for Amateur Built Aircraft by virtue of a delegated authority from the Minister of Transport. They are required to issue the SCofA if they determine the aircraft is a) safe, b) meets all applicable requirements as defined in the CARs and c) is constructed in accordance with accepted practices (see AC 43.13-2B - Acceptable Methods, Techniques, and Practices - Aircraft Alterations).

MD-RA inspectors are not allowed to apply personal preferences / biases etc to the inspection. They are to be impartial and objective.

What the above means is that inspectors have no authority to tell you HOW your project must be modified to come into compliance. They are limited to identifying deficiencies. It is up to the builder to take corrective action and demonstrate the deficiencies have been corrected.

For example, under CAR 549 (not the exemption) there is no stated requirement for a gascolator. Therefore an inspector has no legal authority to tell you that you must install a gascolator.

Effectively, the inspector must cite the basis for any and all "snags" arising from their inspection. They must be specific so you know what the deficiency is. A general statement like "not meeting the requirements C52E" of should not be accepted by the builder. It is your right to know the specifics. How can you correct a deficiency of you don't know what it is?

To use a sports metaphor, inspectors are referees. They are not players in the game nor are they rule makers.

If an inspector snags your project without stating the basis for the snag, I recommend that confirm the issue with Al Mahon the MD-RA general manager. If the snag is not resolved, a complaint with the TCCA program manager responsible for MD-RA would be warranted.

By way of background, in 2012 my first RV10 was inspected by TCCA inspectors after an engine change. I used CAR 549 (not the Exemption) and the TCCA inspectors agreed that gascolators were not required. My inspection was unremarkable and efficient.

In 2019 my second RV10 was inspected by MD-RA (also under CAR 549) and was snagged for the lack of a gascolator. The inspector did not care that my first RV10 was passed by TCCA. He was equally unimpressed with an email from TCCA (Ian Sturgeon) which stated that inline filters and lowest point drains in the fuel system were acceptable as a gascolator replacement for CAR 549 and Exemption based inspections). I appealed to TCCA and was subsequently given an SCofA - with no changes to my fuel system.

In late 2021 MD-RA snagged an RV14 builder for failure to comply with C52E - his fuel system was identical to mine. His SCofA was issued after appeal to TCCA.

Earlier this month another RV10 builder was snagged for not meeting the requirements of C52E. His SCofA was issued after appeal to TCCA.

Inspections can and should be a positive experience for builders. If the inspector finds legitimate snags that is a positive thing as correcting them will make your project safer.

Finally, keep in mind that MD-RA inspectors are volunteers. Be polite and respectful. If you cannot reach agreement on an issue, handle the issue when responding to the snags.
__________________
Les

RV10 C-GCWZ Sold and now vacationing in Tulsa
RV10 C-GROK Flying
RV10 # 3 - under construction

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