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Mounting small cameras in aircraft
The airworthiness regulations are primarily about certifying the approved design of aircraft and required operational equipment, manufacturing those products and thereafter ensuring they remain airworthy.
The continuing airworthiness and maintenance regulations are framed in relation to the approved design and the terms aircraft components (CAR) and aeronautical products (CASR). Aircraft components and aeronautical products include parts of aircraft as specified in the Part 21 approved design of the aircraft, and equipment required by the regulations for operation of the aircraft.
On occasion we are asked about the rules and requirements for mounting small cameras in aircraft, particularly whether the airworthiness regulations apply.
A small camera is not considered an aircraft component or an aeronautical product if it is:
- not included in the approved design of the aircraft
- mounted in a way that does not affect the approved design of the aircraft
- not required equipment for the operation of the aircraft.
Mounting a small camera in accordance with the above criteria is not a change to the approved design of the aircraft and is not maintenance of the aircraft.
The approved design of the aircraft would be affected by physical changes to a part of the aircraft, such as drilling holes. The approved design of the aircraft would not be affected by mounting means such as a suction cup.
Under CAO 20.16.2, a small camera that meets the above criteria is cargo. It is therefore the operator and pilot in command’s responsibility to ensure that the camera is used, restrained and stowed in compliance with CAO 20.16.2 so that the safety of the aircraft is not adversely affected. A formal approval from CASA or a Part 21 design organisation is not required in these circumstances.
The physical size of the camera is a relevant consideration for mounting and safe operation. The mass and dimensions of the camera are relevant for considerations such as the suitability of mounting means and the mounting location.