ARC Renewal When the Maintenance Programme Was Not Followed
A non-commercial owner operates a Cessna 172 under a CAR-M continuing airworthiness management arrangement with a small CAMO. The aircraft's ARC expires in three weeks. During the pre-ARC review, the CAMO's airworthiness review staff notice that two scheduled inspections from the approved maintenance programme were missed eight months ago, although subsequent inspections were done and no defects were recorded. The aircraft has flown 60 hours since the missed items. The owner pressures the CAMO to issue the ARC because the aircraft "is obviously fine" and a delay would disrupt a planned family trip. The CAMO's procedures require a satisfactory airworthiness review before recommending the ARC. The missed items are recurring inspections of flight control cable tension and a fuel system check.
1. Can the CAMO issue the ARC now? Explain the airworthiness review logic and what must happen first.
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No. An ARC is a statement that the aircraft is airworthy at the time of issue and that the airworthiness review has been satisfactorily completed. The review must confirm that the aircraft conforms to its type design and is in a condition for safe operation, including that the approved maintenance programme has been complied with.
Two recurring inspections were missed. Even though later inspections were done, the missed items were not accomplished at the required interval, so programme compliance is broken. The review cannot be signed off as satisfactory until the missed inspections are performed (or otherwise addressed per approved data) and any findings rectified. 'It flies fine' is not an acceptable substitute.
Required actions before ARC:
- Perform the missed flight control cable tension and fuel system inspections per the maintenance programme/AMM.
- Rectify any defects found.
- Record the accomplishment and close out the finding.
- Complete and sign the airworthiness review, then issue the ARC (or recommend it to the competent authority if the CAMO lacks privilege).
Pressuring the CAMO to skip this is a direct conflict with CAR-M and the CAMO's own procedures.
2. If the inspections are completed and pass, but the ARC cannot be issued before expiry, what options exist and what are the consequences of flying after expiry?
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If the ARC cannot be issued before expiry:
- The aircraft may not fly (other than under a specific permit/authorisation) once the ARC has expired, because it is no longer airworthy for flight under the applicable rules.
- The CAMO should complete the review promptly; if the review is satisfactory, the ARC can be issued with the new validity.
- In some frameworks a short extension or a ferry permit may be available from the competent authority for a specific flight (e.g., to a maintenance base), but this is not a general permission to continue operating.
Consequences of flying after ARC expiry: the flight would be unlawful; insurance may be invalidated; the owner and possibly the CAMO face enforcement; and the pilot/operator commits a breach of airworthiness requirements. The correct advice is to complete the inspections and review, issue the ARC, and only then fly. The planned trip is not a justification.