PHYSICAL INSPECTION AND SAFETY REVIEW OF AIRCRAFT TO BE DECLARED
1.Introduction For the purposes of this AMC, ‘physical inspection and safety review’ includes: a. the investigation prior to the issuance of a permit to fly, which consists of a physical inspection of the aircraft by the competent authority; and b. the investigation prior to the approval of the flight conditions, which consists of a physical inspection and assessment of the aircraft by EASA.
2.Purpose The purposes of the physical inspection and the safety review prior to the approval of the flight conditions and the issuance of a permit to fly for a particular aircraft design for which the declarant intends to submit a declaration of design compliance are: a. for EASA to ensure that the design configuration, for which the flight conditions have been requested for the compliance-demonstration activities under point 21L.A.44, is capable of conducting safe flight during flight testing and that the design is sufficiently mature so as not to pose an unacceptable level of risk; b. in case the declarant is a declared design organisation, for EASA to conduct the first oversight visit in accordance with point 21L.B.183(b) of Subpart J in order to ensure that the declarant is able to discharge its obligations; Note: Under Subpart C of Section A there is no obligation for a declarant to submit a declaration of design capability and become a declared design organisation. c. for the competent authority to ensure the conformity of the aircraft with the configuration for which the issue of a permit to fly has been requested. d. for the competent authority to: i. either, in case the declarant is a declared production organisation, conduct the first oversight visit in accordance with point 21L.B.143(b) of Subpart G and point 21L.B.241 of Subpart P in order to ensure that the declarant is able to discharge its obligations and is capable of producing or controlling the production of aircraft, products and parts that conform with the design data; ii. or conduct a first oversight visit of the production organisation that intends to issue statements of conformity for aircraft, which conform to a declaration of design compliance, to ensure that the production organisation is capable of discharging its obligations under Subpart R.
3.Methodology and evidence The physical inspection and the safety review should be conducted by EASA and the competent authority at an appropriate location(s) selected by the declarant. This (these) location(s) should include the physical location of the aircraft for which the approval of the flight conditions and the issuance of a permit to fly have been requested and should be in the principal place of business (which in accordance with Article 8(2) of Regulation (EU) No 748/2012 must be in an EU Member State). The Agency and the competent authority should conduct a physical inspection of the aircraft, engine or propeller for which the approval of the flight conditions and the issuance of a permit to fly have been requested. This inspection, along with any other activity that EASA or the competent authority deems necessary (for example, see point 21L.A.44(f)), should ensure that the objectives mentioned in point 2 are met. Additional sources of evidence during the visit at the declarant’s facilities may include: a. witnessing or participating to live testing of the aircraft, engine, propeller, systems or components; b. review of the completeness of the compliance-demonstration plan produced by the declarant; c. review of the maturity of the supporting compliance documentation and test reports; d. discussions with key design and production personnel; e. review of conformity documentation; f. review of the relevant design or production processes and procedures (for non-approved organisations). The above list of additional sources of evidence is not exhaustive.
4.Aircraft condition and configuration The aircraft presented to EASA and the competent authority should be in a condition for first flight and be in the configuration for which the approval of the flight conditions and the issuance of a permit to fly have been requested. If this is not the case, then a judgement should be made whether the safety review and physical inspection can be conducted or not based upon any differences between the ‘as presented’ configuration and condition and the configuration that will be used for flight testing.
5.Availability of supporting documentation and key personnel The declarant is required to make available supporting documentation and conformity data at the time of the visit by EASA and the competent authority at the declarant’s facilities. Key design and production personnel should be made available by the declarant to EASA and the competent authority in case of need. The Agency and the competent authority may wish to withhold the approval of the flight conditions and the issue of a permit to fly if this is not the case.
6.Findings and resolution If a non-compliance is discovered by EASA or the competent authority in the process of the activities mentioned in point 2, an appropriate finding may be raised against the particular aircraft or, if applicable, the declared design organisation or declared production organisation. Depending upon their nature, these findings may need to be resolved before the flight conditions are approved or the permit to fly is issued.
7.Duration and schedule The physical inspection and safety review may be a single visit or multiple visits depending on the complexity and the maturity of the design. It should not solely be viewed as a single one-day event.