The first annual inspection– proposed under Part 43

Learn more about the initial annual inspection on an aircraft once Part 43 is made and commences.

Who should read this

  • Licensed aircraft maintenance engineers
  • Registered Operators
  • CAR30 organisations
  • Part 145 Approved Maintenance Organisations

When is an aircraft due for an inspection under Part 43?

Under Part 43 most aircraft will be required to undergo an inspection every 12 months — the annual inspection.

The first annual inspection to be carried out on an aircraft under Part 43 may appear daunting due to the requirement for the Authorised Inspector (AI) to determine whether the aircraft conforms to its type certification basis as properly altered.

Note: reference to an authorised inspector (AI) means a holder of an inspection authorisation (IA).

This information sheet provides detail on the first annual inspection in two parts:

  • a visual condition inspection
  • a review of the aircraft paperwork.

What happens during a visual condition inspection?

During a visual condition inspection there should be no requirement for an AI to dismantle the aircraft other than opening or removing all necessary inspection plates, access panels, cowls, fairings and floor coverings.

The scope and detail of Part 43 Appendix D generally specifies inspections for visible or apparent things such as looseness of attachments, cracks, improper installation, improper function, excessive leaks, undue or excessive wear and poor general condition. It is not intended to be a detailed and deeply intrusive inspection.

The FAA guide for an AI states:

The inspection itself is essentially a visual evaluation of the condition of the aircraft and its components and certain operational checks.

It is very important that the holder of an IA be familiar with the manufacturer's service manuals, bulletins, and letters for the product being inspected. Use these publications to avoid overlooking problem areas.

In many cases the aircraft will already be known to the AI who will be familiar with its maintenance history and under those circumstances, the first annual inspection should be a straightforward task.

Most aircraft are unlikely to require extensive additional inspections or rectification work however in some cases, additional work may be required to bring an aircraft into conformity with its type certification as properly altered.

Note: only undocumented major repairs or alterations will require rectification before further flight.

What happens during a paperwork review?

During this review the AI will:

  • inspect the aircraft documentation for airworthiness directive (AD) compliance
  • check that the required placards and documents set forth in the aircraft specifications, flight manual or type certificate data sheet are available and current
  • check that major repairs or alterations have been made in accordance with approved data.

If an AD that applies to the aircraft has not been complied with, the AI may either:

  • carry out the AD (with the approval of the RO)
  • list the AD as a defect and disapprove the aircraft for return to service.

My aircraft may have already had modifications carried out, how will this affect the first annual inspection?

Under Australian legislation, all aircraft modifications and repairs prior to the implementation of Part43 have been required to be carried out under the control of an approved maintenance organisation, using data approved either by a former CAR 35 delegate, a CASA delegate or a subpart 21.M approval holder.

If a repair or alteration is recorded and certified in the aircraft's maintenance records, including a reference to the data used, the maintenance record certification may be accepted as evidence the data has been properly approved and the work has been completed in accordance with that data.

The AI will not be required to review the data or inspect the work to determine the work conforms to the data – this has already been accomplished under previous legislation.

What happens if an undocumented modification or repair is detected?

Some aircraft owners and maintenance organisations may have incorporated unapproved repairs or modifications, but it is considered unlikely that many such unrecorded repairs or modifications will be major in nature and require subpart 21.M approval.

If an unrecorded repair or alteration is found during an annual inspection, the AI has the option to:

  • if the repair or alteration is a minor repair or alteration:
    • inspect the repair or alteration to determine the work is acceptable and if so, release the aircraft to service
    • contact the RO for related information
    • list the work as a discrepancy and disapprove the aircraft for return to service.

Note: in regard to, minor repairs and modifications it is within the scope of either the LAME or the IA privileges to assess the work and determine that it meets the relevant regulatory requirements. The Authorised Inspector is only required where the repair/modification is found to be major.

  • if the work is a major repair or alteration:
    • contact the owner for related information
    • conduct an inspection and approve the work for return to service if approved data is available
    • list the work as a discrepancy and disapprove the aircraft for return to service.

What happens if my aircraft is not approved for return to service?

If your aircraft is not approved for return to service, the IA is required to:

  • provide you with a signed and dated list of defects and/or discrepancies
  • make an entry in the aircraft records stating that an annual inspection has been carried out, the aircraft is disapproved for return to service and the registered operator has been given a list of defects and/or discrepancies
  • if items of operational or emergency equipment are not required to be operational, the AI must placard the control or instrument as "inoperative".

If any of the listed defects are required to be rectified before further flight, you may arrange for the AI to affect the rectifications or arrange for a LAME of your choice to do the work. Once the rectifications have been certified as completed by a LAME, the aircraft may be returned to service—no further AI inspection will be required.

If it is necessary or preferable to fly the aircraft to another location for the rectifications, you must obtain a Special Flight Permit from CASA or an authorised person.

Disclaimer

The content provided in the information sheet is a guide only as to how the rules may work in practice once Part 43 is made and commences.

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Online version available at: https://www.casa.gov.au//first-annual-inspection-proposed-under-part-43
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