Document 176649

Certificate of Inspection Authorisation
IA certificate issue
Recent Experience Requirement
Phase 1 - Type Conformity
Data plates
Replacement data plates
Design Changes
Modifications and repairs
Approved modifications and repairs
Supplemental Type Certificates
Modification Parts
Special Category – Experimental Aircraft
Phase 2 Maintenance Record – Audit
Aircraft Documents
Maintenance Programme
Approved Maintenance Programme
Maintenance Requirements and Responsibility
Phase 3 – General Condition Inspection
ARA Documentation
ARA administration
Reporting of defects – Part 12
Certification of conformity
Form 337 Distribution
Frequently Asked Questions
• failure of motive power
IA means the holder of a certificate
of inspection authorisation.
• unintentional operation of, or any inability
to operate, any systems or equipment
essential to the safety or operational
function of the aircraft
LAME means a licensed aircraft
maintenance engineer.
Major modification means a modification
that could potentially affect the safety of an
aircraft or its occupants where, as a result
of its embodiment, one or more of the
following may occur:
• incapacitating injury to any occupant
• unacceptable unserviceability or
Technical data are drawings, instructions,
or other data required to be used for product
certification, approvals, and authorisations
under Part 21 Certification of Products and
Parts or for the maintenance, modification,
and repair of products, their components,
and appliances under Part 43 General
Maintenance Rules.
• structural collapse
• loss of control
• failure of motive power
• unintentional operation of, or inability
to operate, any systems or equipment
essential to the safety or operational
function of the aircraft
• incapacitating injury to any occupant
Airworthy condition means the condition
of an aircraft, including its components, fuel,
and other materials and substances essential
to the manufacture and operation of the
aircraft, that complies with all the
requirements prescribed by the Rules relating
to design, manufacture, modification, repair,
and safety.
• unacceptable unserviceability or
Major repair means a repair that, if carried
out, could potentially affect the safety of an
aircraft or its occupants where, as a result
of its embodiment, one or more of the
following incidents may occur:
• structural collapse
• loss of control
of Inspection
• have passed an examination in airframe
overhaul that is acceptable to the Director.
Subject 009 is an acceptable examination
in airframe overhaul for those engineers
that held a licence, or held a valid credit
for subjects 003 and 004 prior to 1 April
1997. For those engineers gaining a valid
examination credit for subjects 003 and
004 after 1 April 1997 the successful
completion of these subjects also provides
a credit against the airframe overhaul
examination requirement, and
The annual review of airworthiness (ARA) is
a monitoring process designed to ensure that
aircraft maintained in under Part 43 General
Maintenance Rules continue to comply with
their Type Certificate or properly modified
condition, and that the aircraft is maintained
in an airworthy condition.
• have successfully completed a course of
instruction and passed a written examination
on the examination of aircraft and
components for conformity with the Civil
Aviation Rules, conducted by an organisation certificated under Part 141 Aviation
Training Organisations – Certification.
The Certificate of Inspection Authorisation
qualifies experienced Licensed Aircraft
Maintenance Engineers to certify ARAs, and
conformity of major repairs and modifications
to acceptable technical data.
It does not permit the holder to approve
technical data.
Other requirements are detailed in Part 66,
rule 66.9 Issue of licences, certificates and
ratings and include meeting fit and proper
person criteria, competency in the English
language, and ensuring that the issue of the
certificate will not be contrary to the interests
of aviation safety.
Candidates for an IA must:
• hold a rated aircraft maintenance engineers
licence issued under Part 66 Aircraft
Maintenance Personnel Licensing, or an
equivalent Australian aircraft maintenance
engineer licence registered in New Zealand,
in both aeroplane and powerplant or
rotorcraft and powerplant categories, and
IA certificate issue
The certificate is issued separately to the
aircraft maintenance engineer licence, but is
designed to fit in the same laminated wallet.
It is issued for five years and is renewed via
application Form CAA 24066/05. As part of
the renewal process, IAs are required to attend
a refresher course/seminar conducted by the
Director. The certificate may be suspended
or revoked in accordance with the Civil
Aviation Act.
• at the time of application for the certificate
have held the licence for at least 60 months,
and met the recent experience
requirements of 6 months in each 24
months over that period. (The experience
may consist of exercising the privileges of
the licence or supervision of aircraft
maintenance in an executive capacity),
The New Zealand Gliding Association issues
the certificate to its engineers.
These applicants must successfully complete
a course and examination conducted by the
Director or by an organisation certificated
under Part 149 Aviation Recreation
Organisations – Certification.
The ARA can be conducted only within the
Part 43 environment, and only by an IA.
ARAs are required for:
• aircraft issued with a standard, restricted
or special category Airworthiness Certificate
conducting private operations, and
Recent experience requirement
• aircraft — conducting air transport
operations, with nine seats or less,
excluding the pilot’s seat — which the
operator elects to maintain outside of a
Part 145 maintenance organisation.
The recent experience requirement of
Part 66, rule 66.207 Recent experience
requirements may be met by conducting
within the preceding 12 months:
• four ARAs, or
• The ARA applies to type-certificated aircraft
(including gliders) as detailed in the
previous paragraph, gliders, warbirds
and amateur-built aircraft.
• four certifications of conformity of major
repairs or major modifications, or
• a combination of ARAs and conformity
certifications totalling four.
The ARA is not required for:
If the recency requirement cannot be
achieved by the conduct of ARAs or
conformity certification, it is acceptable to
complete at least eight hours of refresher
training or complete an examination
acceptable to the Director. Check with the
CAA that the course you are considering is
acceptable. The Inspection Authorisation
examination conducted by Aviation Services
Ltd meets this requirement.
• aircraft conducting air transport and
maintained in a Part 145 organisation, or
• microlight aircraft.
ARAs must be conducted by IAs. No part of
the review may be delegated.
The IA does not need to be rated on the
aircraft in question but must be familiar with
that aircraft. A good example would be a
turbine-powered variant of a group 1
helicopter, when the IA holds only the group
1 rotorcraft rating. To be familiar with a
type, the IA must be able to demonstrate
extensive practical experience to a level at
least equivalent to that required for rating
issue, have a good working knowledge of
applicable Airworthiness Directives, service
information, and the manufacturer’s
maintenance manual.
The ARA should not be confused with the
process of maintenance review. This is carried
out by air operators who maintain their
aircraft at maintenance organisations
certificated under Part 145 Aircraft
Maintenance Organisations – Certification.
It is not acceptable for an IA holding the
aeroplane and powerplant categories only,
to conduct an ARA on a helicopter, unless
that IA has rotorcraft practical experience
equivalent to the level required for the aircraft
maintenance engineer licence rotorcraft
category and rating issue.
have not been issued for older aircraft types.
In these cases, airworthiness data is attached
to the airworthiness certificate in the form
of operating limitations.
An IA must be able to demonstrate a level of
familiarity with the aircraft type that will
allow him or her to detect modifications to
the type design.
Aircraft issued with special category
experimental Airworthiness Certificates are
not required to meet the type conformity
requirements of the ARA. These aircraft types
will include warbirds, amateur-built and other
non-type-certificated aircraft. Some warbird
aircraft may have restricted Airworthiness
Certificates. In these cases, type conformity
is required. Check for an exemption against
type conformity for these specific aircraft.
The ARA can be considered to contain three
• type conformity
• logbook audit
• general condition inspection
Data plates
These three elements are required by Part 43
(rule 43.153).
Identification of products and parts is
required by Part 21 Certification of Products
and Parts Subpart B. These rules relate to
New Zealand-manufactured aircraft, engines
and propellers.
Phase 1 — Type conformity
The aircraft under review is required to
conform to its Type Certificate. It must be
audited against the type certificate data
sheets (TCDS) and other technical
documentation that forms part of the of
the approved type design.
Imported products should carry the
identification information required by the
regulations of the country of manufacture.
For example some countries may not require
data plates to be installed on propellers.
The data sheets (previously known as aircraft
specifications) are available for many aircraft
of United States manufacture on computer
software. These are available from a number
of outlets including the FAA web site at
In many cases propellers carry engraved or
stamped identification information directly
applied to the product rather than on a
separate plate. (This may not be visible
without removing the mounting plate.)
The data sheets are less readily available for
other foreign aircraft. If you have difficulty,
contact the Aircraft Certification Unit of the
CAA for assistance. Some older aircraft do
not have data sheets or aircraft specifications.
In these cases the flight and maintenance
manuals should provide sufficient information.
In a very small number of cases, flight manuals
The first step in establishing type conformity
is to locate the aircraft data plate. The rules
of the country of manufacture will detail the
required position of the data plate. The FAA
and CAA require the plate to be located at a
point near the main entrance of the aircraft
or at a point on the empennage where it can
be seen by a person on the ground.
For example, some Blanik gliders imported
from the USA have the plate located near this
tail position.
powerplant, or similar locations, if such
design changes are not recorded in the aircraft
maintenance records.
The plate should be assessed against the data
sheets to ensure correct aircraft type, model
and serial number. This should be followed
by an assessment of the major components
to ensure the powerplant, propeller and
components agree with the data sheets, a
Supplemental Type Certificate, or other
approved design change.
Modifications and repairs
Modifications recorded in the aircraft
maintenance records at the time of initial
Airworthiness Certificate issue are considered
to have been approved by the issue of the
certificate. This acceptance method also
applies to avionic installations recorded
on the Form CAA 2129 at the time of the
initial Airworthiness Certificate issue prior
to 1 April 1997.
If the aircraft or major components do not
comply with the data sheets, aircraft
specifications, or its properly modified
condition, the aircraft does not comply with
its Type Certificate, and this should be entered
in the aircraft maintenance records as a
Modifications noted during the ARA that are
not recorded in the aircraft records cannot
be accepted as being approved. Typical
modifications, not recorded in the
maintenance records, that an IA would be
expected to observe during an ARA include:
Replacement data plates
If a data plate has been lost, replacement
action must be made in accordance with
Part 21 (21.807 Removal, alteration and
replacement of identification information).
This can be carried out only with the approval
of the Director and the manufacturer.
One example of a manufacturer’s procedure
requires at least two affidavits and an aircraft
inspection by a designated person acceptable
to the manufacturer. Other manufacturers
require a letter of support from the CAA.
• non-standard powerplant or propeller
• interior refurbishment
• avionic installations not included on the
Form CAA 2129
• installation of speed fairings, droop wing
tips, or winglets
• installation of camera hatches
• installation of externally mounted
attachments including mirrors, or handles
for parachute drop operations
Design changes
• installation of cargo panniers or skidmounted ski racks
Type conformity also means that all design
changes have been approved. An IA must be
sufficiently familiar with the aircraft
undergoing review to identify any visible
design changes. The IA cannot be expected
to identify design changes that are within
closed structure, internal areas of the
This list is by no means complete. It is designed
to provide examples of common unapproved
or unrecorded modifications discovered
during the first 12 months of the ARA. These
discrepancies must be recorded and reported.
rule 91.627 Maintenance records requires the
operator of an aircraft, except a class 1
microlight, to compile maintenance records
for major modifications and major repairs.
Modifications and repairs that are not by
definition major are considered maintenance,
which has the same recording requirement.
Approved modifications and repairs
The IA must ensure that modifications and
repairs noted on the aircraft under review
have been certified in the aircraft records
and, where applicable, are approved.
When the maintenance records show that
the required approval has been gained and
the certification is made in accordance with
the Rules or regulations in force at the time
of the certification, generally no further
action is required from the IA. It is not
expected that an IA should gain copies of
the technical data contained in approved
modifications or repairs for assessment against
the installed modification or repair.
Responsibility for this belongs with the
operator. If unrecorded modifications or
repairs are observed on an aircraft, they must
be listed as discrepancies. It is not the
responsibility of the IA to gain approval for
these items, but the operator may contract
the IA to assist with approval, using the
Form CAA 337.
Many aircraft will have been modified or
repaired in areas that, because of the nature
of the structure, will not be visible to the IA
during the ARA. The IA is not expected to
identify unrecorded repairs or modifications
of this nature.
The certification of release to service by
the LAME, and reference to approval
identification data at the time of embodiment
of the modification or repair, provides a
statement that the work has been properly
carried out and that airworthiness has been
maintained. The only exception is when the
modification or repair is observed as not
complying with technical data contained in
an approved modification or repair scheme
known to the IA.
In cases where maintenance records have
been lost or destroyed, recertification of
known modifications and repairs is required.
Owners/operators unable to locate historical
maintenance records should contact the CAA
Aircraft Certification Unit for guidance.
If in doubt, the CAA can provide limited
information, such as whether a listed
modification or repair is approved and what
the approval covered. The CAA cannot supply
copies of approved technical data for
confirmation purposes, as this data is
proprietary and belongs to the approval
Supplemental Type Certificates
Some design changes, such as the addition
of speed fairings or drooping wing tips, are
embodied on an aircraft under the authority
of a Supplemental Type Certificate (STC).
STCs issued by the FAA and CASA, and
Supplemental Type Approvals issued by
Transport Canada, are acceptable technical
data included in Appendix D to Part 21
Acceptable technical data, subject to some
conditions. IAs should ensure that the
maintenance records show that the
A wide general knowledge of common repairs
and modifications incorporated in an aircraft
type is considered part of the familiarity
requirement for IAs.
Part 91 General Operating and Flight Rules,
certificate. Major repairs and major
modifications to this category of aircraft do
not require certification of conformity to
acceptable technical data contained in
Appendix D to Part 21.
modification or repair is a genuine STC.
A lack of complete certification in the
maintenance records may indicate a locally
manufactured copy. The FAA now requires
the installer to have the permission of the
STC holder, therefore a photocopy of STC
data is not acceptable
Repairs and modifications should be recorded
in the maintenance records, and the method
of repair or modification approval should be
detailed. This category of aircraft may have
modifications and repairs approved under
Part 21 Subpart C Design changes, or, in some
cases, via an in-flight evaluation programme
(see Advisory Circular 21-3A Product
certification – Airworthiness certificates in
the special category). Aircraft within this
category that have a type design or
supporting technical data, (eg, warbirds)
should be repaired or modified in a manner
that ensures the aircraft retains the type
design. Repairs should be carried out in
accordance with manufacturer (or military
operator) manuals and, when the scope of
the repair falls outside of these manuals, data
approval should be requested.
Modification parts
Parts incorporated in a modification must
be approved parts as described in Part 21,
Subpart K Materials, Parts, Processes, and
Appliances and Advisory Circular 20-2
Acceptability of parts. Of particular
interest is rule 21.303(2) Replacement and
modification materials, parts, and appliances,
which permits the use of parts that shall:
“be manufactured for a person to install
on their own product and comply with the
type design of the product, including any
embodied design changes”.
These parts require specific product
identification marking (see Advisory Circular
21.80A Identification of products and parts
– Identification information, provision, and
replacement) and could be installed on an
aircraft at the owner’s request via Form CAA
337. Typical examples of this type of modified
product that IAs may observe are the tailskids
fitted to some gliders. Logbooks, or other
maintenance records should document the
design change. If no record exists, a
discrepancy should be actioned.
Amateur-built aeroplanes are issued with
experimental certificates and are also subject
to the above. A large number of these aircraft
do not have repair manuals. Major repairs
and modifications to these aircraft require
that the aircraft be returned to a flight test
programme to prove the repair or
modification by in-flight evaluation. The repair
or modification should be carried out using
technical data such as FAA AC 43-13.1B
Acceptable Methods, techniques and Practices
– Aircraft Inspection and Repair, the original
aircraft drawings, or designer supplied data,
and it should be released to service by an
appropriately qualified person (for details
see Part 43).
Special Category – experimental
Aircraft issued with special category
airworthiness certificates are not required to
be reviewed for type conformity, as these
aircraft are not supported by a type
Aircraft documents
The following items summarise the purpose
and process of this phase of the ARA:
The following documents are required by
Part 91 (91.111 Documents to be carried) to
be carried in the aircraft. The IA must ensure
that they are in place:
• This phase addresses the aircraft’s
continued compliance with its Type
• current Airworthiness Certificate
• Identify the aircraft and its major
components by reference to data plates
or other approved identification marking.
Ensure correct type, model and serial
numbers are applicable. Ensure logbooks
refer to the correct aircraft or component
by type, model and serial number.
• current version of the Flight Manual (special
category aircraft may have operating
limitations in place of the Flight Manual)
• Ensure observed modifications are
approved and recorded.
In addition to the above items, Advisory
Circular 43-10 Aircraft radio station requires
that the Form 2129 be placed in the flight
• Tech Log
• Certificate of Registration for New Zealand
aircraft operating overseas
• Ensure observed major modifications and
major repairs carried out after 1 April 1997
have been certified for conformity to
acceptable technical data in the
maintenance records.
Maintenance programme
Rule 43.153 Rule requirements requires
the IA to ensure that all due maintenance
specified in the applicable maintenance
programme has been completed. The first
step in meeting this requirement is to identify
what programme the aircraft is being
maintained to. Operators must provide a
tech log for each aircraft. One of the
mandatory items to be recorded on the Tech
Log is details of the maintenance programme.
The IA should check the maintenance records
to verify that the aircraft is being maintained
to the stated programme.
This phase is carried out on aircraft issued
with standard or restricted Airworthiness
Certificates including gliders.
This phase is not required on aircraft issued
with special category Airworthiness
Certificates, although modifications must
still be recorded in the maintenance records
including the method of approval. For
amateur-built aircraft the approval may
be by in-flight evaluation.
Phase 2
Maintenance record – audit
Approved maintenance programme
The second phase of the ARA consists of an
audit of the aircraft maintenance records.
Usually this means the aircraft logbooks, but
the records could be of any format acceptable
to the Director.
‘Approved’ means approved in writing by
the Director. An approved programme will
contain evidence of this approval via
signature or official stamp. Certain aircraft
require approved maintenance programmes.
to the operator after an ARA. For this reason
the certification of the review contains the
words, “the requirements of Parts 91 and 43
have been complied with”. This statement
reinforces the fact that the process is a review
of the aircraft airworthiness status, it does
not indicate future compliance with the rules.
They are:
• aircraft with a MCTOW of greater than
5700 kg
• turbine powered multi-engine aircraft
• turbine powered rotorcraft
• aircraft issued with a special category
airworthiness certificate
Operator responsibilities are detailed in
Part 91 (rule 91.603 General Maintenance
Requirements) and include ensuring:
Maintenance programmes for gliders may be
approved by a Gliding Association (certificated
under Part 149) as detailed in Part 104 Gliders
– Operating Rules. Also, the Sport Aircraft
Association of New Zealand (previously known
as NZAACA) develops customised programmes
for their members’ amateur-built aircraft
from a master programme approved by the
CAA. It is important that IAs ensure that if
the approved programme for an amateurbuilt aircraft is recorded as being the Sport
Aircraft Association programme, this is the
inspection schedule that is being used. It is
not acceptable to identify this programme
but physically carry out the Part 43 Appendix
C (Annual and 100-hour) inspection.
• aircraft are maintained in an airworthy
• applicable Airworthiness Directives are
complied with
• inspections required by Part 91 Subpart G
are carried out
• airworthiness limitations in a
manufacturer’s maintenance manual, or
contained in an approved maintenance
programme, are complied with, including
component finite lives
• any item of equipment or any instrument
permitted inoperative by rule 91.537
(Inoperative instruments and equipment)
is removed, repaired or replaced at the
next required inspection
Maintenance requirements and
Part 91 Subpart G Operator maintenance
requirements places the responsibility for the
maintenance of an aircraft upon the operator.
In practical terms the operator is the only
person that has both operational and
maintenance control of the aircraft at all
times. The operator may contract with a
maintenance organisation for the
maintenance control of an aircraft, but
the overall responsibility still remains with
the operator.
• any permitted inoperative equipment or
instruments are placarded
• except when the discrepancy relates to
permitted inoperative instruments or
equipment, all discrepancies have been
rectified in accordance with Part 43,
between inspections
• no person performs maintenance on the
aircraft other than those persons
authorised in the rules.
The IA has no control over the maintenance
actions that occur once an aircraft is returned
The function of the IA during this phase of
the ARA is to ensure that all required
• completion of previous annual reviews of
maintenance has been carried out and
certified on time or within the specified hourly
period. To satisfy this requirement, the aircraft
records should be examined for release to
service statements for:
• rectification of discrepancies including
those listed on the Tech Log
• re-calculation of weight and balance
information as required
• inspections required by an approved
maintenance programme (when the aircraft
is required to be maintained under this
type of programme)
IAs that have computer access, may elect to
subscribe to the CAA web site’s free notification
service. This service will forward an email
message to the subscriber when a change has
occurred to rules or Airworthiness Directives
that the subscriber has registered an interest
in. The web site address is
• annual or 100-hour inspection (for aircraft
not requiring an approved maintenance
• replacement of life-expired components in
accordance with the airworthiness
limitations section of a manufacturer’s
maintenance manual
During the review of the maintenance records
the IA must also ensure that entries fully meet
the requirements of rule 43.69 Maintenance
records and 43.115 (2) or 43.117 (2) Recording
of post inspection ground run results. These
rules require the recording of parts release
document information, component part and
serial numbers, results of any measurements
or tests carried out (including the maximum
height an altimeter has been tested to), and
details of post-inspection engine ground runs.
• radio station test and inspection every
24 months
• altimeter (if applicable to the aircraft being
reviewed and no current rule exemption
exists) and altitude reporting equipment
test every 24 months, and when the static
lines have been disassembled (other than
self sealing couplings), or when maintenance
on the system could have introduced data
correspondence error (see rule 91.613)
Weight-and-balance information contained
in the maintenance records must indicate
that the aircraft is within the limitations of
the aircraft Type Certificate.
• SSR transponder test and inspection every
24 months
• ELT test and inspection every 12 months
Modifications and repairs noted on the
aircraft during phase 1 or 3 of this review
should be researched in the maintenance
records. Major modifications and major
repairs carried out after 1 April 1997 must
have a certification of conformity to
acceptable technical data entered in the
record by an IA, unless the repair or
modification has been carried out by a
Part 145 organisation.
• repetitive or initial Airworthiness Directive
• compass compensation as applicable
• safety equipment including fire
extinguishers and flotation equipment
every 12 months (see Advisory Circular
43-6 Emergency equipment)
• duplicate inspections when control systems
have been disturbed
• All visible modifications and repairs are
approved and have been released to service.
Reference to the approved technical data
for each modification or repair should be
contained in the maintenance records.
Modifications or repairs not recorded in the
records cannot be accepted as approved.
If identification of a modification is proving
difficult, the CAA may be able to provide the
operator with modification ownership details,
but technical data contained within a
modification is considered to be the property
of the modification owner and cannot be
released by the CAA.
• Identification and markings required by
Parts 47 Aircraft Registration and Marking
and 26 Additional Airworthiness
Requirements are in place and legible.
Check whether exemptions to these
requirements are in force.
Modifications should be approved via the
Form CAA 337 process.
• The minimum instruments and equipment
required by the rules meet the appropriate
standards. The standards may be as
contained in Part 91 Appendix A Instrument
and equipment specifications, or Appendix
C to Part 21, or Part 26 or alternative
specifications or standards that are
acceptable to the Director. The instruments
and equipment must have been installed
in accordance with the aircraft
manufacturer’s instructions or other acceptable technical data. The instruments and
equipment must be in operable condition.
Phase 3 – General condition
The purpose of the general condition
inspection is to provide the IA with confidence
that the maintenance records reviewed in
phase 2 reflect the actual physical condition
of the aircraft under review.
This inspection is not the 100-hour/annual
inspection detailed in Part 43 Appendix C.
However, if the IA is also carrying out the
100-hour/annual inspection, the general
condition inspection could be satisfied as
part of this.
• Refurbished interiors are documented in
the aircraft maintenance records, including
evidence that the materials meet the
flammability standards required for type
certification of the aircraft.
The general condition inspection should
address the following items:
• The visible aircraft structure is free from
defects that should have required a nonrelease to service statement being entered
in the aircraft records in respect of
corrosion, wear, leakage, etc. The aircraft
condition should clearly indicate that all
required inspections and maintenance
actions have been completed fully.
The aircraft condition should fully reflect
the aircraft status contained in the
maintenance records.
• Aircraft radio station approval (form
CAA2129) reflects the actual avionics fit
installed in the aircraft.
• Placards required by the data sheets,
specifications, CAA Rules or flight manual
are correctly in place and legible.
• Documents to be carried, ie, Airworthiness
Certificate, Tech Log, Form CAA 2129 and
Flight Manual (not required for all gliders
– see Part 104) are on board and current.
The current Flight Manual status can
be accessed from the CAA web site, or hard copy will be
provided to IAs on request.
checklist containing discrepancies as a looseleaf logbook entry is acceptable, but it is
preferred that discrepancies be entered
directly into the logbook.
When recording discrepancies on the
checklist, those items that have been rectified
should be noted in the appropriate section
of the form.
ARA documentation
Due to the extensive nature of the ARA it
is important that the IA use a checklist to
assist with recording each step of the review.
The checklist must contain at least the
information contained in the Form CAA
24066/06 for fixed-wing or CAA 24066/07
for helicopters. The checklists are available
from the CAA in hard copy and on the
CAA web site.
If an item is worn or corroded but is within
published limits or, in the absence of
published limits, does not affect structural
strength or other airworthiness requirements
(see Part 43.53 (a)(10), it is not a defect.
The IA may wish to list any item that is not
a defect but does indicate deterioration of
the aircraft. The checklist should clearly
indicate that it is only an observation and
be entered in the remarks section.
The completed checklist should be
forwarded to the CAA, and a copy should
be passed to the owner/operator for
retention with the aircraft records.
The purpose of forwarding a list of
discrepancies found during the ARA to
the CAA, is to provide statistical data on
the continuing airworthiness status of
New Zealand-registered aircraft, that are
subject to the review.
The ARA is a snapshot of the aircraft
airworthiness status at the time the review
is conducted. The review should be conducted
as a single process and the discrepancies
noted at the completion of the review.
Remember that the ARA is not maintenance,
and rectification action is not part of the
If an owner/operator requests the IA to
rectify discrepancies after the review, the
rectification action should be recorded in
the report to the CAA.
If an owner/operator chooses to have a
pre-ARA survey carried out to rectify any
suspected discrepancies, discrepancies
encountered must be entered into the aircraft
records and are subject to normal release-to
-service action.
ARA administration
Once the ARA has been completed and
discrepancies recorded, the IA must enter in
the logbook or other approved technical
record, the full statement contained in rule
43.155 Certifying review, the IA’s signature,
IA certificate number, and the date. The date
of the next ARA must be entered in the
appropriate section of the Tech Log.
Discrepancies noted during the ARA are to
be entered into the logbook or other approved
technical record, and advised to the Director.
A copy of the checklist containing the
discrepancies is an acceptable method of
advising the Director. Placing a copy of the
The certification of the ARA does not rely on
the discrepancies being rectified prior to its
issue. It is the operator’s responsibility to
ensure the aircraft is not flown with a
discrepancy. IAs must ensure that the
certification of the ARA is not carried out
before the full review process is completed.
It is not acceptable to certify a partial review.
of Conformity
The certification of conformity of major
modifications and major repairs is also a
privilege of IAs. The IA may not approve
technical data but does perform a conformity
inspection to ensure that major repairs and
major modifications conform to acceptable
technical data.
The certification of the review is a statement
that the ARA has been completed. It says that
the airworthiness requirements for the aircraft
have been met over the past 12 months – it
is not a release to service.
LAMEs certifying release-to-service statements
for repairs and modifications must assess the
repair or modification against the definition
of a major modification or major repair.
The definition is contained in Part 1 Definitions
and Abbreviations. Advisory Circular 43-9A
Modifications, repairs and the Form CAA 337,
provides further information and guidance
on typical repairs and modifications that
should be considered major.
of defects –
Part 12
IAs must be familiar with this AC. The Form
337 has a dual purpose:
It is possible that, after the ARA has been
completed, the IA may have recorded
discrepancies found during the general
condition inspection that are defect incidents
that must be reported in accordance with
Part 12 Accidents, Incidents and Statistics.
The IA should be familiar with Part 12
requirements and the additional information
in Advisory Circular AC12-1 Mandatory
occurrence notification and information.
The person discovering a defect incident
(an incident that involves failure or
malfunction of an aircraft or aircraft
component, whether found in flight or on
the ground) must forward the incident details
to the CAA within 10 days. If the incident is
a serious incident, the CAA must be notified
as soon as practicable.
• approval of technical data
• conformity certificate
IAs must not certify the conformity statement
of the Form 337 prior to the technical data
being approved.
• If the Form 337 relates to a major
modification or repair that utilises
acceptable technical data listed in Part 21
Appendix D, the originator, (usually the
LAME) should complete the Technical Data
Classification block (block 5) of the form
by ticking the “is approved” box and
completing the information within this
block. The LAME may now request the IA
to conduct the conformity inspection on
the completed work and certify the
conformity inspection in block 7.
Asked Questions
• If the technical data is not acceptable data
as listed in Part 21 Appendix D, and
therefore requires approval, the data
should be attached to the Form 337 and
forwarded to the CAA or a certificated
design organisation for approval. In this
case block 5 should be ticked to indicate
approval is required. The IA must not certify
conformity in block 7 at this point as the
data is not approved. Once the Form 337
has been returned from the CAA or design
organisation as approved, the IA may be
requested to conduct and certify the
conformity inspection.
The following list of frequently asked questions
are provided for the guidance of IAs.
1. Can an IA delegate the ARA to an
appropriately rated licensed aircraft
maintenance engineer?
Answer: No, the IA must complete all sections
of the ARA.
2. If a modification is observed and the
maintenance records contain an entry for
the modification that includes a reference
to its approval and a release to service,
does the IA need to gain a copy of the
approved modification to verify it?
The conformity inspection should consist of:
• review of the technical data to ensure it
is acceptable technical data (Part 21
Appendix D) or that the data has been
Answer: No. However, if the IA is familiar
with the modification and realises that it
has been improperly carried out, it should
be entered as a discrepancy.
• review of the work completed to ensure
that it has been carried out in accordance
with the approved technical data
3. When carrying out the ARA on an
amateur-built aeroplane, what form of
modification approval should the IA
look for?
Form 337 distribution
Form 337 is completed in duplicate. One copy
is forwarded, once action regarding the
certification of conformity is complete, to
the CAA for the aircraft’s file. The second
copy is retained as part of the aircraft
maintenance records.
Answer: Modifications to this category of
aircraft may be substantiated by in-flight
evaluation. If a major modification has been
carried out, the owner should have
contacted the CAA regarding placing the
aircraft into a test programme within a
restricted area. Certification of conformity
of major repairs and modifications via Form
CAA 337 is not required for aircraft with
special category Airworthiness Certificates.
4. If a periodic inspection has been certified
in the logbook and the entry refers to the
inspection title and a work package, should
the IA check that all relevant entries in
the work package have been certified
7. Is an ARA required on a newly imported
aircraft that is undergoing initial
airworthiness certificate issue?
Answer: Yes, if the aircraft is being
maintained under the Part 43 ARA process.
(Private operations, or air transport flights
on aircraft with nine seats or less operating
under Part 135.)
Answer: The IA should check that all due
maintenance has been carried out. The
logbook entry for the inspection that
contains a release-to-service statement, and
refers to the inspection title and the work
package, is sufficient evidence that the
required inspection has been completed.
It is the responsibility of the certifying
Licensed Aircraft Maintenance Engineer to
ensure that all entries in the work package
have been correctly certified before issuing
a release-to-service statement.
8. If an IA finds a defect on an aircraft
during the ARA, can that defect
rectification be deferred to allow the
aircraft to return to base?
Answer: The rules are no different in respect
of an ARA to the standard defect
rectification requirements of Part 43 and
91. If the aircraft does not have a Minimum
Equipment List, no defect rectification can
be deferred other than the items detailed
in rule 91.537 (Inoperative Instruments and
Equipment). Items that show deterioration
that is not beyond manufacturer’s limits, or
published standard practices contained in
acceptable technical data (see Part 21), are
not defects and may be recorded in the
maintenance records and monitored in
accordance with the maintenance record
5. Does an IA have to use the CAA Forms
24066/06 or 07 as a checklist when
completing an ARA?
Answer: The use of a checklist is required as
an acceptable method of recording the
review actions. The CAA Forms 24066/06 or
07 are an acceptable checklist. However,
IAs may design their own checklist provided
they ensure that it contains at least the
same information as the CAA form.
Example: RH MLG Scissor link bush Part
number xxxxx found worn. Bush inspected,
found within manufacturers limits (refer
Manual xx Fig 3). Bush to be reinspected at
next 50-hour inspection.
6. Can an ARA be deferred?
Answer: No. But the ARA may be completed
early if realignment to other scheduled
maintenance is required.
9. During an ARA the IA notices significant
corrosion on the aircraft structure.
The maintenance records indicate that
the corrosion has been noted and is to
be monitored. Should the IA record the
corrosion as a discrepancy?
record an assessment of the affected area
and the basis for the aircraft being considered
fit for release to service, ie, reference to
acceptable technical data in respect to the
assessment. If an assessment is not recorded
in the maintenance records or the corrosion
is believed to be affecting the aircraft’s
structural strength, then a discrepancy must
be entered onto the ARA checklist.
Answer: This depends upon the extent and
location of the corrosion, and any published
10. During an ARA, the IA notes minor
surface corrosion or other items which,
if not addressed, may become defects,
but at the time of the review, the aircraft
is fit for release to service. The IA wishes
to draw these items to the operator’s
attention and record them for future
assessment. Should these items be recorded
as discrepancies.
The bottom line is that defects cannot be
deferred, other than items falling under
Part 91, rule 91.537. Part 43, rule 43.53
requires that persons performing
maintenance shall ensure that, on
completion of the maintenance (this includes
an inspection) the aircraft or component
shall be fit for release to service, and at
least equal to its original structural strength.
In the absence of published limits, the LAME
must ensure that the aircraft is at least
equal to its original structural strength. The
presence of corrosion has a direct impact
on structural strength. Therefore, if corrosion
is present, the maintenance records should
Answer: The CAA check list Form CAA
24066/06 (fixed wing) or 07(rotorcraft)
contains space in which remarks may be
placed. If the item noted is not a defect it
may be recorded here. It should not be
recorded as a discrepancy.