[chepburn]

---See clarification as a reply below---

There is a possible serious issue brewing in Canada with respect to conflicting requirements for pre-cover and/or final inspection of RV fuselages.

Some builders have been advised that is it OK to inspect the fuselage at 'final' pre-flight inspection only. As long as all areas of the structure are 'inspectable', such as under the floor and the forward baggage area.

Builders have proceeded on the fuselage construction based on this premise.

Recently, a builder has been told that his aft turtle deck skin must be removed to facilitate an additional pre-cover inspection. The builder has rightly disputed this request, but is meeting resistance from the MDRA.

I am now unsure on my own position with respect to my final inspection sometime next year.....my aft skin is riveted on as well. I have added removable panels everywhere else so that the inspector may see hidden structure as required. Besides, the there is NOTHING that is hidden in the aft area even if the skin is ON!!!

I feel that the possibility of REMOVING my aft skin for inspection will possibly harm my aircraft structure which negates the safety aspect of an inspection.

MDRA is looking into this issue.

Chris

 

[llavalle]

Good info.. I've been following this issue on the Ottawa RVAtor Google Group as well....

Thx, I'll file a complain!

 

[Tom Martin]

Please talk to your local MDRA inspector before sending off a flurry of emails. I have been working with MDRA and various inspectors for years and have always found them to be supportive.

 

[Norman CYYJ]

I second what Tom Martin has said. I too have been working with the MD-RA for years and have found them very good to work with.

Norman

 

[chepburn]

Please talk to your local MDRA inspector before sending off a flurry of emails. I have been working with MDRA and various inspectors for years and have always found them to be supportive.

I have talked to my inspector before I took action. He, unfortunately, will be bound by the MDRA if Transport Canada issues a rule clarifying the current issue, and it is not in the builder's favour.

There is a formal process in place, which we, as builders, have been instructed to use by Transport Canada. I would prefer my formal, dated request be in TC's hands BEFORE the ruling is made, so that I have some grounds to apply for a waiver from TC when my final inspection date rolls around.

My inspector is on my side. But, he may be forced to change his position.

Chris

 

[chepburn]

The MDRA has responded to this issue

I have talked to my inspector before I took action. He, unfortunately, will be bound by the MDRA if Transport Canada issues a rule clarifying the current issue, and it is not in the builder's favour.

There is a formal process in place, which we, as builders, have been instructed to use by Transport Canada. I would prefer my formal, dated request be in TC's hands BEFORE the ruling is made, so that I have some grounds to apply for a waiver from TC when my final inspection date rolls around.

My inspector is on my side. But, he may be forced to change his position.

Chris

The MDRA has responded to this issue. You cant say that there are not responsive!!!!

The bottom line is that all structures require a pre-cover inspection as per TC rules.
HOWEVER, if the builder provides access to ALL hidden structure, it is possible to perform a 'pre-cover' of the fuselage at the time of 'final' inspection if the builder has not covered structural components.

This is good for us, but RV8 builders will have to make sure they have inspection ports in the forward area baggage compartment ,where there is hidden structure, as well as making sure the aft cabin floor is inspectable.

Expect further clarification.

Chris

 

[chepburn]

Canadian MDRA Response to Inspection Concerns

Hi All,

The following email stream is in newest to oldest order. It contains a clarification from the Canadian inspection authority (MDRA) on what a ?pre-cover? inspection means on an RV fuselage.

Basically, the MDRA is always trying to improve, and they are listening to us. We should make sure the dialog continues.

Chris


<From MDRA>

I will not repeat what I forwarded to your fellow builder as you have clarified you have read it and are satisfied with my response. Transport Canada?s rules are the same throughout Canada and our Inspectors are trained and instructed to follow policy and procedures evenly. When an Inspector attempts to remedy a builders unfortunate situation or builders specific requests, the builder tends to spread the word through other builders that there is now a new policy, and before we know it, builders assume there has been an official regulation change. I do apologize for any inconvenience this clarification may have caused you and all others.
Your email clarifies you understand and are complying with the regulations. I would like to thank you for your comments and I would like to suggest clarification of this matter be distributed through the RV builder?s network.
MD-RA Inspection Services has recently completed our Bi-annual recurrent training and re-certification of all our 60 inspectors in Canada. Our system isn?t perfect but I have realized more information and education is required for builders and MD?s a like.
Our web sight is scheduled to expand into several different areas? early in the New Year. A FAQ section is a great suggestion.
Contact the MD-RA office for any inspection question you may have.

Please do not hesitate to contact me with any question, suggestion or enquiry, I would be very happy to assist you.

Sincerely
...
MD-RA Inspection Services
www.md-ra.com
1-877-419-2111


<To MDRA>

Sir,

Your response <below> satisfies my concern, and I have requested a pre-cover inspection of my fuselage in its present condition, so that I do not have to worry about it for another year while I complete my other systems.

For your general information, I think we as builders get very concerned when there seems to be a different level of compliance for different builders?I know that information tends to get distorted the more times it goes ?around the campfire?. I do not envy you folks your jobs of having to deal with us.

We depend a lot on previous builder?s experience to determine what is, and what is not required to comply with our inspection requirements.

It seems that there are many different ?rules? that get distorted (or not). Ie The use of gascolators on FI engines, The use of Halon, What constitutes ?inspectable? etc etc

I realize that there will always be differences between inspectors, and, there will be no ?one size fits all?. However, it would be ?nice? if a builder could go to MDRA to determine fact from fiction?.CAR 549 sometimes leaves us a bit short.

Maybe an approved ?Frequently Asked Question? section.

Thanks for your work,
?.


<From MDRA to Another Builder>

Chapter 549, 507 exemption Appendix "A" is very clear, All area's not accessible at time of Final inspection must be subjected to a pre-cover inspection.

A pre-cover of a fuselage has been a requirement of the Minister for years. For anyone to say a pre-cover inspection is not required is incorrect.

The inspector has the prerogative to perform a pre-cover at another time or at time of Final as long all area's are open to allow for the inspection. Your quote, "as long as I made appropriate access panels and removable floors" will allow for the inspector to view what would normally be closed. Therefore as long as you have complied with the inspector?s request, you should have no problem.

Please contact the inspection office and request a Pre-cover inspection and if ready request a Final.
This action is not a new Policy, but rather actions that have recently came to our attention.

Please understand our actions and policies are regulated by Transport Canada, not MD-RA in London.

Best Regards
?.
MD-RA Inspection Services
www.md-ra.com
1-877-419-2111


<To MDRA>

Subject: The requirement of a fuselage pre-cover inspection on the RV family of aircraft.

Hello,

I am writing this email because I have a concern and require a clarification on the requirement of a ?pre-cover? inspection for my Van?s RV-8 fuselage.

I have progressed my build to the point of the final assembly based on the premise that the fuselage is FULLY inspectable at the final pre-flight inspection as per CAR 549.1

Lately, some fellow builders have been told that an additional pre-cover inspection is required for the RV fuselage, BEFORE the aft turtle deck skin is riveted on.

This is news to me, as I have already progressed my build past this stage, and feel that I would actually be jeopardizing the structural integrity of my aircraft if I had to drill off this skin for another inspection. I understand the requirement of having to view all hidden structure, and I have installed removable floor panels and inspection ports to allow for inspection of these areas for the inspector, as well as for myself to make sure that the aircraft REMAINS airworthy.

I am formally requesting that I be allowed to proceed to final inspection stage on my aircraft, provided that my aircraft?s structure is viewable by my inspector during my final inspection.

I have also submitted a CAIRS letter of Concern, stating my position, so that this issue can be addressed for all future builders.

Thank you for clarifying this issue for me,

?..