Frequently asked questions

Depending on the category, number and nature of the findings detected and recorded by the inspectors during the ramp inspection, several measures may be taken.

If the findings indicate that the safety of the aircraft and its occupants is affected, corrective measures may be required by the inspected person prior to its resumption of operation or the need to establish limitations on its flight. The collaboration of the Command Commander/PiC (PIC) of the aircraft will normally be required to deal with the most serious findings and measures, but any duly accredited representative appointed by the operator (TMA, F/O, etc.) may assume such responsibility.

In general, if category 3 findings have been detected, these will generally involve the operator taking ‘corrective measures before authorising the flight’ to rectify the identified deficiencies. In other cases, where such measures cannot be taken, it may be necessary to establish operational restrictions or limitations, as discussed above, which may range from requiring the application of operational (O) or maintenance (M) procedures as contained in documents such as the Minimum Equipment List (MEL) for uncorrected defects that can be dispatched or others set out in the Operator’s Operations Manual (OM) to the application of other more restrictive measures in accordance with other documents approved by the Supervisory Authority (e.g. EASA, in the case of operators, aircraft or registrations registered in the Spanish Register of Registrations) equivalent.

In rare cases, in situations where inspectors detect a lack of cooperation or even a lack of explicit intention on the part of the Aircraft Command Commander/Pilot to take the necessary action in respect of the findings communicated to it, the inspectors shall first force the aircraft to remain on the ground, an act which will be formalised by the authority. The official act of immobilisation by the inspecting State means that the aircraft is prohibited from resuming its flights until appropriate corrective action is taken, and occurs whenever the operator intends to undertake the operation without addressing the serious deficiencies identified, contrary to the criteria of the inspectors, as provided for in Regulation (EU) No 965/2012, ARO.RAMP.140, in Article 30: Extraordinary measures of Law 21/2003 of 7 July 2003 on Aviation Safety, Title III: Aeronautical inspection, and Articles 33 and 43 of provisional and extraordinary measures respectively contained in Royal Decree 98/2009 of 6 February 2009 on Aeronautical Inspection Regulations.

No non-compliance is considered as long as the operator has communicated the schedule to the crew members in sufficient time to enable them to plan their rest (ORO.FTL.110a).

If the crew member is aware of the schedule of their flights (flight activity) or of any other task assigned by the operator (activity, imaginary, bookings...) at least 14 days in advance, they can plan their pre-activity rest.

Please note that:

• Before a flight duty period there must be a rest period (based on 12 hours). ORO.FTL.235 (a)
• the definition of rest period is: “uninterrupted and defined period of time during which the crew member is relieved of any service, the provision of imaginary at the airport, and the reservation”. ORO.FTL.105 (21)
• The definition of service (or activity) is “any task performed by a crew member for the operator, including flight duty, administrative work, giving or receiving training and verification, positioning, and some elements of the imaginary” ORO.FTL.105 (10)

Point CAT.GEN.MPA.100 (b)(4) on crew responsibilities provides that the crew member “shall respect all flight and service time limitations (FTL) and rest requirements applicable to their activities”.

In accordance with the regulatory point ORO.FTL.230; ORO.FTL.235:

Before a FDP period, you must always give the required rest in ORO.FTL.235 (12 hours on base, 10 hours off base or the previous activity if higher). Therefore, if there is no such rest before the reservation, this rest must be guaranteed between the notification of the activity and the report. NOTE: The above reply corresponds to an assigned FDP during the first day of booking. If it is an assigned FDP during a booking day preceded by a booking day on which no activity assignment has occurred, the 10-hour notification of the reservation would be sufficient.

Yes, according to regulatory point ORO.FTL.245 (b):
‘On request, the operator shall provide copies of individual records of flight times, duty periods and rest periods:

1. the crew member concerned, and (
2. another operator, in respect of a crew member who is or becomes a crew member of the operator concerned.’

However, paragraph (a) of the same point provides that the mandatory period for the operator to keep individual records for each crew member is 24 months.

The rules on flight time limitations and rest periods, as set out in Subpart ORO.FTL, apply to flight and cabin crew members. In addition, in cases of carriage of cargo in the passenger cabin, it is also required to be applied to cargo surveillance personnel in flight.

However, there is no specific similar legislation applicable to land workers, the labour regulations and collective agreements being applicable.

The crew responsible for supervising the cargo shall be considered cabin crew and shall therefore respect and follow flight time limitations as they act as responsible for monitoring the cargo status and reacting in case of an emergency.

In Spain, as a member of ICAO (Instrument of Ratification published in BOE No. 55 of 24 February 1947) and of the European Union (Instrument of Ratification published in BOE No 1 of 1 January 1986), the SAFA/SACA Inspections are part of the Rampa Inspection Programmes developed by ICAO from which the European Commission’s SAFA Inspection Programme was derived, after which EASA extended it to air carriers within the EU with SACA inspections.

The main regulations that apply to SANA Inspections are as follows (listed not exhaustive):

a. INTERNATIONAL AND EUROPEAN FRAMEWORK:

(1) Chicago Convention on International Civil Aviation of 1944, Article 16. Aircraft inspection; and its derivative Annexes
2) Regulation (EU) 2018/1139, Chapter IV, Article 62 and its derived technical regulations, including:

I. Regulation (EU) No 965/2012, Annex II, Subpart RAMP;
II.    Regulation (EU) No 1321/2014,
iii.    Regulation (EU) No 1178/2011,
iv.    Regulation (EU) No 748/2012,
v. Regulation (EU) No 923/2012,

B. NATIONAL MARCO

1) Law 21/2003 of 7 July 2003 on Aviation Safety;
(2) Law 48/1960 of 21 July on Air Navigation;
3. Royal Decree 98/2009 of 6 February 2009, Aeronautical Inspection Regulations; and
4) Law 39/2015 of 1 October 2015 on the Common Administrative Procedure of Public Administrations.
5) Royal Decree 184/2008 of 8 February 2008 approving the Statute of the State Aviation Safety Agency
6) Technical regulations, including:

I. RD 750/2014
ii.    RD 384/2015
iii.    Technical standard of ULM.

The detail for the execution of ramp inspections is developed by the European Aviation Safety Agency (EASA) in EASA’s Rampa Inspection Manual, which details inspection instructions and procedures.

In accordance with the regulatory point ORO.FTL.105 (8): 
Oh, yeah, yeah. What defines whether late completion is the duty period, thus including post-flight duty.

The first step should be to obtain the certification in Spain of your exact ULM model. This certification process must be carried out by the manufacturer. Once the ULM type certification has been obtained in Spain, the enrollment process will be possible.

Procedural information and form can be obtained on the AESA website