The checks in the mail.
Your airplane will be ready Tuesday.
Im from the FAA and Im here to help you!
Three of the Great Lies – but with the last, you actually have some control over what happens. If your encounter with the FAA involves a ramp check, there are several things you can do to protect yourself, including knowing what an inspector may and may not do, that may help it it go easier.
Getting ramp checked is one of the great fears of all pilots. Even the average, law-abiding pilot has a gut-level dread that no matter how righteous his intentions, the FAA inspector will find something wrong with either the pilot or the plane. Many fear that they will either get temporarily stuck at a distant airport or, worse, face an enforcement action with a license suspension.
Many people would say its a given that that no airplane is completely FAR-compliant if examined closely enough. We all know legally airworthy and safely flyable are independent issues that may overlap but certainly do not have to. The fear of being caught with some minor, seemingly unimportant discrepancy makes pilots tremble at the approach of an inspector on the ramp.
Whats a Ramp Check?
The FAA General Aviation Operations Inspectors handbook calls it surveillance of an airman, operator or air agency during actual operations at an airport or heliport. The official purpose for ramp checks (ramp inspections in FAA parlance) is to determine that an airman or operator is in continuing compliance with the FAR during an actual operational situation.
An operator may be a pilot, an executive/corporate operator or an air agency – which means you, if you flew the plane in, no matter who owns it. Thats particularly significant if youre flying a plane belonging to an FBO, club, or another individual. Under the FARs, you as pilot in command are completely responsible for that aircrafts airworthiness. Any discrepancies in the logs, certificates/documents or material condition of the aircraft can be laid on your head for enforcement purposes.
When Do Ramp Checks Happen?
Murphy would suggest the best way to guarantee a ramp check is to forget your pilot certificate, as thats the first item theyll want to see. But the truth is that most pilots never get ramped. Why? First, there just arent that many FAA inspectors covering GA, and their time is booked pretty solid with accident and enforcement investigations, routine certificate issuances and monitoring Part 135 operators.
Furthermore, the FAA budget is pretty tight these days, and they dont have overtime to hang around GA airport ramps on weekends. During the summer, they spend some weekends surveilling air shows and the larger/busier fly-ins. However, their handbook tells them their primary purpose at those events is safety and monitoring flight operations for waiver compliance.
Ramp checks without serious cause are inappropriate. Mass or random ramp checks are out. The FAAs book says three common reasons for a ramp check of any Joe who happens by are that the inspector:
• Observes an unsafe operation in the traffic pattern or on the ramp.
• Is notified by ATC of an unsafe operation.
• Conducts normal surveillance – the random check.
There are times when the inspector will come out looking for someone in particular to inspect. This would be an individual who is the subject of recurring complaints or suspected of violations of the FARs, or who is involved in operations targeted by a special emphasis program required by the regional office or headquarters. An example of the last category might be someone seen loading boxes labeled Oxygen Canisters in the months after the ValueJet accident.
If youre a weekend GA flyer and dont do anything to attract attention (like handpropping a plane solo with no tiedowns or chocks, or landing at a Class B airport without talking to tower or approach), your likelihood of being ramp checked gets pretty small. Personally, Ive flown nearly 6,000 hours without ever being so honored.
There are others who have been ramped three times in one year, although they generally are those involved in Part 135 operations, which is a separate chapter in the inspectors book and much higher on the priority list.
While youll find that the fear of a ramp check is much more prevalent than the actual event, it can happen. If it does, the inspector has very specific guidance on how to do his job. First, the inspector must identify himself, including presenting his credentials. Then, he conducts the inspection, which is for a light GA aircraft, divided in four parts – pilot documents, aircraft documents, aircraft inspection and a review of the findings.
Pilot Documents
The inspector will start with your pilot and medical certificates. The FARs require you to present them for inspection by any FAA or NTSB inspector, or any law enforcement officer. There is a false belief around that present means show but does not require give. This will get your ramp check off to a real bad start.
You must hand the certificates to the inspector so he can determine if [they] are genuine and legible; if theyre OK, the inspector is required to hand them back. Some folks are under the impression that simply handing your certificates to an inspector can be considered surrendering them, as in giving them up for good. This is not true.
To surrender your certificates, you must fill out and sign a form letter that explains both your intent to surrender, and your understanding of what surrender means. You have no lawful reason for not handing them over once the inspector has properly identified himself, and the inspector cannot keep them if theyre OK.
The inspector will check that the certificates are current and appropriate for the flight. If you jumped out of the right seat of a twin that landed IFR with a student in the left seat, they will expect to see a current CFI ticket with a multi-engine rating in addition to a pilot certificate with both multi-engine and instrument ratings. They will also expect to see a first or second class medical certificate dated within the previous 12 months, and any waiver you might require.
If youre instructing on a third class medical, expect extra questions to make sure you werent being paid to pilot the plane in addition to instructing. Remember all through the inspection that anything out of the ordinary will draw attention.
The inspector will ask to see your pilot logbook. If you do not have it there, thats fine. He can skip this part, or tell you to bring it to your local FSDO at your earliest convenience (like within a few days, not six weeks from now). If you have it with you, you must hand it over on the spot. If your log is sitting on the seat in the plane, the inspector will see it when he gets in the plane.
Lying to the inspector will get you more of that undesired attention, and hell go over that log with a fine-toothed comb. Basically, the inspector is looking for a BFR or equivalent, landing currency, instrument currency or IPC if you came in IFR, and a PIC proficiency check for two-pilot planes.
If you dont have your logbook with you, you will be able to check those items before you get to the FSDO. This is not to suggest you should pencil-whip your log into shape, but Im sometimes behind in transferring flight data from my DayRunner to my logbook. In a couple of days you can make sure all the flying youve done is completely and properly recorded. This is why many pilots do not carry their logbooks unless required (checkrides or a student going solo cross-country).
Aircraft Documents
For GA, its pretty simple – start with the basic ARROW documents you learned as a student pilot: airworthiness certificate, registration certificate, radio license (if crossing national borders), operating limitations (AFM/POH/placards), weight and balance.
The first two are cut and dried. They must be there, and the airworthiness certificate must be displayed at the cockpit/cabin door and legible to passengers and/or crew. The N-number on the registration must match whats painted on the plane, and the owners name should be current. The radio license is only needed if you crossed a border, but if you landed at Buffalo coming from Toronto, it will be checked, including expiration date.
If youve still got the license that came with the plane when you bought it, youd best get a new one from the FCC. They are not transferable, and the name on the license must match the registration. The weight and balance paperwork will be checked to see that it is current – that the items in the equipment list are actually installed and installed items are listed. This can be a problem for aircraft that have undergone avionics updates. In addition to a 337, the shop should have updated the equipment list for items not already on it. This includes things like replacing older Narco/King/Cessna radios with TKM/Michel slide-in replacements.
The last two items are current, pertinent aeronautical charts and any necessary radio/nav equipment. If you landed off an approach with DME in the name, youd best have a current chart for that approach and a working DME or IFR-certified GPS in the panel.
While VFR pilots need not have current sectionals in the plane, anyone who doesnt will be asked to explain how they complied with FAR 91.103 requirements to familiarize themselves with all pertinent data before the flight, and how they plan to navigate without such charts. The price of a current chart (about the same as five minutes of flying time) is pretty cheap insurance against such a grilling.
While there is no requirement for you to have a filled-out W&B form for every flight under Part 91, you must have assured yourself somehow that the airplane is within W&B limits. You may get away with Ive owned and flown 64U for 10 years, and I know when the load is close enough to limits that I have to run the numbers, but you will then be asked to demonstrate that. I keep W&B sheets with worst case aft c.g./max weight cases with the required W&B documents; anything lighter or more forward is guaranteed in the zone. That way, I have something to point to if the inspector ever asks.
They can also ask for the aircraft logs. As with pilot logbooks, you are not required to have them with you, but if you do, you must hand them over, and you are responsible if theyre screwed up, no matter who owns the plane. This means with other peoples planes, youd be well-advised not to fly it unless you know the logs are kosher. Also, if youre delivering a plane to or picking one up from the shop, your credibility is going to be pretty low if you say the logs are at home.
Aircraft Inspection
The inspector can demand admittance to the aircraft in order to:
• Determine the general airworthiness of the aircraft by inspecting the aircrafts exterior in a manner similar to a preflight inspection.
• Inspect seats and safety belts for installation and condition.
• If applicable, determine if a current VOR equipment check has been performed.
• Determine if an ELT is installed and check the expiration date of the battery.
• Determine that the aircraft identification plate exists and is secured to aircraft fuselage exterior.
The inspector is NOT authorized to require you to start up the plane, although you may be required to turn on the master switch if thats necessary to check fuel gauges in order to confirm fuel loading. The inspector is not supposed to conduct an annual inspection on your plane. If it looks good from the outside, theres no direction in his book to go removing panels, opening up inspection covers or pulling up seats.
If the inspector finds something wrong with your airplane, he must tell you what it is, if it affects airworthiness and if continued operation would be in violation of the FARs. You may receive an Aircraft Condition Notice advising you of the specific condition which the inspector believes renders the aircraft unairworthy.
Operations inspectors (pilot types) are not supposed to issue these on their own. They should have an airworthiness inspector (mechanic type) with them, or coordinate with one at the nearest FSDO before issuing an ACN. If you get an ACN, your aircraft is effectively grounded unless you can prove the condition either does not exist or does not really render the aircraft airworthy.
This must be a clear, documented proof on your part, such as the fact the your Q-tip props are supposed to have their tips bent back, as opposed to Well, I dont think that hydraulic leak is all that bad. If you fly the plane after receiving an ACN, you are guilty until proven innocent, and its a deliberate violation carrying much stiffer sanctions.
Incidentally, you dont have to be present to get an ACN. An inspector who sees something during a casual stroll down the flight line can leave you one if he sees something like obvious damage to a wing, or a deep gouge in a prop blade. The inspectors guide also says, An inspector must not board any aircraft without the knowledge of the crew or operator. No sneak peeks are allowed without specific legal authority like a search warrant.
If the inspector sees something when youre not there, he is supposed to tie the ACN to the plane where the pilot can easily see it. If you find such a card attached to your plane, take it seriously – they keep copies and follow up. If the plane is gone two hours later, you will be called to explain how you fixed the discrepancy that quickly.
Concluding The Inspection
When hes done, the inspector should discuss any pertinent safety information, return any documentation, advise you of any upcoming accident prevention or other safety meetings, and compliment you if no discrepancies were found. (!?!, you say? Yup, hes required to be nice and tell you how good youve been.)
Assuming no discrepancies, youre on your way. If things didnt go so well, you will be told that you may be subject to a compliance investigation if the inspection reveals a possible violation of the FARs. Also, a follow-up inspection may be conducted to determine if any noted discrepancies have been corrected. Since the original ticketing part of the Streamlined AA Program (SAAP) has been dropped, you no longer have to worry about an on-the-spot decision on whether to accept or fight an inspectors findings. Just remember the earlier advice not to fly a plane the inspector says is unairworthy unless you can prove hes wrong.
When Things Go Sour
Some people feel uncomfortable with a one-on-one situation with an inspector. We all know the power inspectors have, and many of the protections that apply to most legal situations dont apply to FAA enforcement proceedings. In such a case, you might want to invite another pilot hanging around to be a witness to the inspection. But be careful how you do it. Make it Freds never seen one of these before, how bout he watches? rather than I want a witness so I can dispute any report you make. Above all, be polite and respectful. While 98 percent of FAA inspectors are good folks, and will treat you the same way, you may run into one of the other 2 percent. What then?
Remember that an FAA inspector has the authority to get a law enforcement officer to assist him in his duties. That officer will have a gun, handcuffs and arrest powers, and you certainly do not want to get to that point. Typically, this is reserved for a reasonable suspicion that you are under the influence of drugs or alcohol and plan to fly anyway.
Even if it doesnt come to such third-party intervention, the FAA has the power to make your life pretty miserable, so its best to use your people skills to keep any disputes low-key. The presence of a neutral party, such as another pilot or airport management, can help keep a lid on any potential confrontations.
If you feel youre being treated unfairly, remember that FAA inspectors all have bosses. Theres a chief operations inspector at the FSDO, and an FSDO manager over him. If the FSDO is open, suggest that youd like to speak with the inspectors supervisor. If not, politely suggest that you wish to continue the conversation in the supervisors office when it reopens.
If you dont get in the plane and fly away, there isnt much the inspector can do to you before the supervisor gets involved. The worst thing would be to tell the inspector to take a hike, jump in the plane and crank it up. That will definitely get you face time in the FSDO, and will severely prejudice your case with the higher-ups.
Another pilot asked me once, If you are ramped, is it true they have the right to go through the airplane even if takes all day, even if you had a plans to get somewhere? The inspectors book says, If the surveillance will delay a flight, the inspector should use prudent judgement whether or not to continue. …The inspector should also bear in mind that he or she may not be able to complete all items on every ramp inspection.
You can invoke the delay clause if you really have to be somewhere. Examples of legitimate reasons might be that youve waited an hour for your IFR clearance and youve got a 10 minute void time or that you want to be home by sundown as youre not comfortable with your night proficiency. (Do not try this if youre going to spend the next two hours in the coffee shop.)
A ramp check is, in many ways, a no win situation – the best that can happen is you dont lose. But going into it with a negative or confrontational attitude is a lot like asking the cop who pulled you over, Wassamatta, officer, is Dunkin Donuts closed?
Knowing what to expect, what you can do, and how to prepare are the most important things in dealing with it. And since everything theyre checking is things you should have done anyway, it should be easy.
-by Ron Levy
Ron Levy, an ATP and CFII, is an assistant chief flight instructor at American Eagle Flight Academy.
