Ramp Inspection: Rating Mismatch and Expired Medical
An NCAA inspector conducts a ramp inspection at Lagos on a Nigerian operator's Boeing 747-200F. The Flight Engineer's licence shows a Boeing 727 type rating only, but he is occupying the FE station on the 747 and has signed the load sheet as FE. His Class 1 medical certificate expired six days ago. The crew duty record shows 15 hours 10 minutes on duty in the last 24 hours, including a 2-hour positioning flight. The operator's ground manager explains that the FE is 'under supervision' of a company check engineer who is also on board, and that company policy allows supervised operation during a type transition. The check engineer's licence does carry a 747 rating. The inspector must decide what to do with the aircraft, the FE and the operator before the next sector.
1. Identify the apparent violations and state the inspector's immediate actions.
Read the worked answer
The apparent violations are cumulative:
- No type rating: The FE holds only a B727 rating but is operating the FE station on a B747 and signing as FE. A type rating is required for the aircraft type; the 727 rating does not authorise 747 duties.
- Expired medical: The Class 1 medical expired six days ago, so the licence is not valid for the exercise of privileges.
- Duty limits: The recorded 15 hours 10 minutes in 24 hours may exceed the applicable flight and duty time limits, and must be checked against the operator's approved scheme and the Nig. CARs.
- Possible false certification: Signing the load sheet as FE when not qualified may be a false or misleading record.
Immediate actions: remove the FE from duty, inform the commander and operator, copy the licence, medical, duty record and load sheet, interview the FE and check engineer, and issue a ramp inspection report. The aircraft should not depart until a qualified and medically valid FE is on board. The inspector should consider detaining the aircraft only if the operator cannot replace the FE promptly; otherwise the enforcement action follows the crew and operator.
2. Does supervision by a company check engineer cure the missing type rating or expired medical? Explain the distinction between training supervision and licensing.
Read the worked answer
No. Supervision is a training or oversight arrangement; it does not create licence privileges. The check engineer's 747 rating is personal to him and does not extend to the FE.
A person may occupy a crew station without the type rating only if the regulations and the operator's approved training programme specifically allow supervised training in that role, and normally not while performing revenue operations or signing operational documents as qualified crew. The expired medical is even clearer: supervision cannot make an invalid medical certificate valid.
Company policy is subordinate to the Nig. CARs and the licence conditions. The ground manager's explanation may be relevant to intent, but it is not a defence to the licensing breach. The inspector should treat the 'supervised operation' claim as an operator control deficiency and check whether the training programme actually authorises it.
3. What enforcement and safety-management follow-up should the NCAA require after the inspection?
Read the worked answer
The NCAA should pursue both individual and systemic action.
- Licence action: Refer the FE for enforcement for operating without the type rating, with an expired medical, and possibly for false certification. The licensing file should be reviewed for any pattern of similar endorsements.
- Operator action: Consider certificate enforcement or a corrective action plan because the operator allowed an unqualified crew member to occupy a required station and signed off a duty record that may breach limits.
- Records: Require the operator to reconcile crew rosters, load sheets and duty records, and to demonstrate how the check engineer's supervision was authorised.
- SMS: Require a safety risk assessment covering type transition, supervision, medical validity tracking and duty-time monitoring. The response should distinguish an honest administrative failure from deliberate concealment.
The inspector should also verify whether the aircraft's next sector can be crewed legally before releasing it from the ramp inspection.