P

prkaye

Well Known Member
Canadian builders - a couple of builders recently have had an issue with an inspector being assigned for final inspection, and that inspector saying that it is MDRA policy that RV's have a fuselage pre-cover inspection with the upper aft fuselage skin off. On the other hand, other builders have had MDRA inspectors do a final inspection without demanding a separate pre-cover inspection for the fuselage, and I have it documented by one MDRA inspector that such a fuselage pre-cover is not necessary, as long as you have removeable access and floor panels for any areas that might otherwise be hidden.
There are also issues where the MDRA seems to be over-stepping its authority by making-up its own requirements, such as demanding a stainless steel heater box, or demanding castle-nuts and cotter pins on certain items, where none of these are legally required.
Just wanted to call out to any other Canadian builders out there and ask what your experiences with MDRA have been like. I'm considering writing a letter to their central office to raise these issues.
Thanks,
Phil
 
I haven't started building yet.
It certainly would be nice to have an "understanding" of generally accepted practices.
 
Phil, there are certainly examples of MDRA inspectors being dogmatic in certain requirements.

The primary function of the inspections are for flight safety. Inspection of the airframe requires reasonable access. It's not reasonable for an inspector to be a midget and crawl around in dark inaccessable areas. I don't think most RV's have a problem with fuselage access as long as the baggage floor is not riveted in place. Leaving the aft turtledeck off seems unreasonable, though.

As for the heater box, it's a potential flight safety issue and it's good advice. It is not a written requirement in my experience, though.

The biggie is castle nuts and cotter pins. I don't think there is anywhere on an RV where a change is required to what Van's recommends. In some kits (especially ultralights) this is a big safety problem.

The best way to resolve this issues is to have a conversation with the inspector early in the project to get advice.

One thing that MDRA inspectors don't touch is electrical and avionics. I think that this is a major shortcoming, especially since many aircraft must be properly wired for the engine to run and virtually all of the instruments require power. I was told a story of an improperly wired RV that had the ignition system connected to the master bus. Turning off the master in flight would kill the engine. A severe safety flaw that is not covered by inspections.

So the MDRA has flaws in execution. All of these are usually solved by involving the inspector right from the beginning and listening to what he or she has to say. I've met a few builders and importers who believe it's their constitutional right to build (or import) their own airplane, then show up at the end of the process and demand sign-off by the MDRA.

Usually this results in a lot of foul language as they are told (in extreme cases) that they can't do what they did. Bad attitudes are then applied on both sides and much energy is wasted. In the cases I know about, it's been the builders or importers that are trying to do an end-run around the system.

All problems can be solved by communications, early and often!

Vern
 
I haven't started yet either. I've found there to be a lack of clear information. The MDRA website seems rather weak to me.
 
i think it really does matter who the inspector is.... if that makes any sense. it seems as though when i ask a question about something, they always say to ask the inspector and then immediately say that they don't like to give out those numbers for people to call.
when i first got started i was just shaking my head trying to figure out what they wanted,etc. it's not a real clear process. we haven't done too much on ours yet... just finished the tail section. i know of one other fella that closed up something or other on his wings and hoped there wouldn't be a problem. i guess it was impossible to build without putting the rivets in. so i'm sure the guy passed it because he could tell 'overall' the quality the builder was producing. either way, it's a pain when you haven't got someone even close by to consult with.
 
It's not reasonable for an inspector to be a midget and crawl around in dark inaccessable areas.
Click to expand...

I don't disagree with this. What I object to is one inspector saying go ahead and build the fuselage without a pre-cover, and then another inspector claiming it's MDRA policy to have a fuselage pre-cover.

As for "good advice" regarding things like stainless steel heater boxes, castle-nuts etc, I certainly don't object to good advice. But the MDRA's mandate isn't to invent new requirements and insist that builders comply with them. Their mandate is to inspect aircraft to ensure that they are built to standards that are already well documented and regulated. They shouldn't insist that a builder have something like a gascolator or a SS heater box without being able to point to a regulation to support this requirement. I have both of those, by the way. I recognize the good advice and am following it, but its been reported that things like this are being presented to builders as requirements, not advice.
 
vlittle said:
Phil, there are certainly examples of MDRA inspectors being dogmatic in certain requirements.

The primary function of the inspections are for flight safety. Inspection of the airframe requires reasonable access. It's not reasonable for an inspector to be a midget and crawl around in dark inaccessable areas. I don't think most RV's have a problem with fuselage access as long as the baggage floor is not riveted in place. Leaving the aft turtledeck off seems unreasonable, though.

As for the heater box, it's a potential flight safety issue and it's good advice. It is not a written requirement in my experience, though.

The biggie is castle nuts and cotter pins. I don't think there is anywhere on an RV where a change is required to what Van's recommends. In some kits (especially ultralights) this is a big safety problem.

The best way to resolve this issues is to have a conversation with the inspector early in the project to get advice.

One thing that MDRA inspectors don't touch is electrical and avionics. I think that this is a major shortcoming, especially since many aircraft must be properly wired for the engine to run and virtually all of the instruments require power. I was told a story of an improperly wired RV that had the ignition system connected to the master bus. Turning off the master in flight would kill the engine. A severe safety flaw that is not covered by inspections.

So the MDRA has flaws in execution. All of these are usually solved by involving the inspector right from the beginning and listening to what he or she has to say. I've met a few builders and importers who believe it's their constitutional right to build (or import) their own airplane, then show up at the end of the process and demand sign-off by the MDRA.

Usually this results in a lot of foul language as they are told (in extreme cases) that they can't do what they did. Bad attitudes are then applied on both sides and much energy is wasted. In the cases I know about, it's been the builders or importers that are trying to do an end-run around the system.

All problems can be solved by communications, early and often!

Vern
Click to expand...

vern must have written while i was... anyway, i do agree with the communication but that is opposite from what MDRA has to say on the phone. and i have phoned more than once.
 
I have worked with a number of inspectors and I consider them a valuable resource. They do this job not for the money, which barely covers their expenses but because they enjoy airplanes and the people who build them.
Here is their website http://www.md-ra.com/ I do not know how they could make the process clearer for a first time builder. Click builder information, it is all there.
Yes there are differences in inspectors but as Vern suggested almost all problems can be averted if you speak with an inspector early in the process and ask what he expects.
 
a good experience with an inspector

I had the pre-cover inspection done a few months ago (Ottawa, Canada). I found the inspector to be reasonable and helpful.
I would be inclined to avoid seeking "formal rulings" from MD-RA or Transport Canada (if there are such things) unless you run into a problem there is no other way to resolve.
Forced into a corner, on record, a bureacracy will take the most conservative and risk averse (to the organisation) approach, and once a ruling is made, all the inspectors (and builders) will be stuck with it. An informal approach strikes me as preferable.
Bill Brooks
Ottawa, Canada
RV-6A finishing kit
 
Having worked professionaly in the aviation field for 30 plus years as an AME(M2) and a Flight Engineer I can understand builders frustrations.
It was my experience that when building my RV that some inspectors seemed to come from a different planet and there was a definite lack of communication between themselves and provincial and/or national heads not to mention not being able to work with a national standard of practices.

In my case it was the weight and balance exercise I was asked to do. Three scenarios were required, the first with a loading of a forward C of G, a rearward loading C of G and finally a gross weight loading C of G. I asked the then Provincial head of MD-RA if I should use published average adult weights and was told to use what ever weights I needed to 'make it work'. As a professional and after doing aircraft weight and balance calculations for more years then I care to remember, I know that gross weight is limited to both structural and operating limitations for take off and landing. Consequently I completed the W and B exercise with these parameters in mind and limiting the gross weights to ensure that the A/C C of G was within limits for take off with max fuel and when landing with minimum fuel. I was wrong. I was told that my figures should be such that gross weight will equal 1800lbs including cargo/baggagethat will be 100lbs and if your landing C of G is out of limits, change your passenger weight to bring the C of G to within landing limits, even if your passenger has to weight 300lbs.
I understand that the inspectors job is to insure that your airplane is safe to fly with in the guidlines as laid out by MD-RA, not their own. this is not to say some inspectors do not give good advise and/or building tips however your decision not to follow them should not be a reason to fail an inspection if you comply with TC and MD-RA regulations and guidlines.
But........sometimes you just have to play the game.
 
I understand that the inspectors job is to insure that your airplane is safe to fly with in the guidlines as laid out by MD-RA
Click to expand...

I'm not sure whether it is within the MD-RA's mandate to lay-out any such guidelines. I would like to see documented evidence on this, but I would suspect all they are really supposed to do is make sure builders follow standards which exist elsewhere, in regulations created by TC.
 
powers of MD-RA

Phil,
you are absolutely correct.
An MD-RA is a "Minister's Delegate - Recreational Aircraft". The Minister is the Minister of Transport, and as a delegate, the MD-RA may only exercise the powers of the Minister in applying and enforcing the applicable regulations.
The MD-RA has no free-standing obligation (or right) to "ensure that your airplane is safe to fly". An MD-RA cannot impose requirements other than contained in the regulations. To the extent that the regulations leave room for discretion to be exercised or for interpretation , an MD-RA may exercise that discretion or interpret the regulation.
A builder should feel free to ask the MD-RA the authority relied upon for any requirement, and the MD-RA should be able to provide it, and distinguish between suggestions, and true requirements that flow from the regulations.
If a builder considers an interpretation unreasonable, or a requirement made that is not supported by the regulations, then the builder is free to seek clarification from the Minister/Transport Canada.
Bill Brooks
Ottawa, Canada
RV-6A finishing kit,
(and federal "bureaucrat")
 
Precover

Phil
It is my understanding that the fuselage requires a precover. If the inspector wants the turtle deck off then I would assume that is his choice. What is the foul with this request? The inspector may have a good reason for this. It may be as simple that he cannot fit in the tailcone of an RV 8 due to his size or age problems. If you are a bit miffed with MDRA, wait till you get to Transport Canada, there the real fun can begin. It is a long haul, try not to sweat the small stuff.
 
well,

I suppose the foul with this request is if one has already gone ahead and installed the skin, which I think is the position Phil found himself in.
Builders should be entitled to rely on known standards/requirements, based on real regulatory requirements, which I think is Phil's very valid point.
Bill Brooks,
Ottawa, Canada
RV-6A finishing
 
Throttle & mixture cable connection nuts

vlittle said:
The primary function of the inspections are for flight safety. ........

The biggie is castle nuts and cotter pins. I don't think there is anywhere on an RV where a change is required to what Van's recommends. In some kits (especially ultralights) this is a big safety problem.
Click to expand...

My experience is from south of the border (Canadian border that is) but is relevant. My DAR had an issue with the metal lock nuts used on the throttle and mixture cables connection to the carb. I have a RV-6 with a RV-7 firewall forward kit/set-up. Van's shows in the drawings these nuts and provides them. My DAR questioned there use and I had to show him that it was to plans. He accepted this and did not require me to change them to a nut and cotter pin. Other inspectors may not.

In defense of Van's use of the lock nuts, they are all metal so heat will not affect them and they are torqued down solidly to the spherical bearing so they will not "work" loose.
 
prkaye said:
I'm not sure whether it is within the MD-RA's mandate to lay-out any such guidelines. I would like to see documented evidence on this, but I would suspect all they are really supposed to do is make sure builders follow standards which exist elsewhere, in regulations created by TC.
Click to expand...

Poor choice of words on my part.
I agree with what you say, however I feel where the problem starts is when an inspector uses his own interpretation of a regulation and/or requirement, material, practice etc. and insists that you must have a certain fitting or fixture made of another material because he knew somebody that or he thinks that.............I think you know where this is going.
If a builder follows the acceptable methods techniques and practices (AC 4313) and complied with requirements stated in CARS there should be no problems.
 
What is the foul with this request?
Click to expand...

As I thought was pretty clearly explained in my post, my issue is with INCONSISTENCY. One inspector tells me to go ahead and build and that fuselage precover is NOT required, and then another inspector is coming along telling builders it IS required. if I get stuck with an inspector of the second mindset, I do NOT want to be forced to disassemble my fuselage. Hopefully the fact that I have saved the email from the MDRA inspector who said to go ahead without a fuselage pre-cover will protect me.
 
prkaye said:
As I thought was pretty clearly explained in my post, my issue is with INCONSISTENCY. One inspector tells me to go ahead and build and that fuselage precover is NOT required, and then another inspector is coming along telling builders it IS required. if I get stuck with an inspector of the second mindset, I do NOT want to be forced to disassemble my fuselage. Hopefully the fact that I have saved the email from the MDRA inspector who said to go ahead without a fuselage pre-cover will protect me.
Click to expand...

Yes indeed, a very real problem. This, I feel, may be because of a lack of indepth technical background in aviation. One has to remember that a vast majority of inspectors have regular day time professions/jobs not remotely related to aviation. This can be common problem with volunteer organizations where people of varying and non related backgrounds with minimum training and guidance are in a position of leadership (why I quit CASARA). A lack of standards/communication leads to inconsistency.
If you can crawl down to the back of your fuselage to buck rivets, your inspector should be able to crawl down there and inspect them.
Good thing you kept the email
 
Transport Canada (Marine) has been this way for over twenty years at least. Recently they have had three inspectors leave for this same reason. Four inspectors in one office and all four request different things and some of them are major.
Get use to it, try to deal with the one that is more reasonable and move on. So far I'm very happy with our MD-RA. The only thing he won't budge on is the gascolator and he says it's above his head.
Ron
 
Ron B. said:
Transport Canada (Marine) has been this way for over twenty years at least. Recently they have had three inspectors leave for this same reason. Four inspectors in one office and all four request different things and some of them are major.
Get use to it, try to deal with the one that is more reasonable and move on. So far I'm very happy with our MD-RA. The only thing he won't budge on is the gascolator and he says it's above his head.
Ron
Click to expand...


slightly OT:

can you remind me why a gascolator is not needed in a FI ?
I read it somewhere before, but forgotten.

TIA
 
So far, I've been quite happy with the local inspector

I've been worried since the beginning, about having issues like those above.

I started out at the MD-RA site, and found it easy to use, for as far as it went.
I phoned and got the name of the inspector I'd be assigned, and contacted him to review my planned inspection points for the project.

I'm not quickbuilding anything, but I am working to the statement "show them every rivet before it's closed up and unavailable to be inspected".

So far that hasn't been any inconvenience to me, but I expect will certainly use more than just two inspections. I could leave stuff open and do a pre-cover and a final inspection only. I looked at this as an unacceptable risk to the project - what if I get to nearly complete, get a pre-cover, and find that there's something they needed that I have consistently missed, or mis-done?

So, for a few more (hundreds of dollars) inspection fees over the course of my $75K+ project, I should arrive at the final inspection with a fist full of more paper, and a lot less trepidation.

The local inspector has been very supportive and helpful.

He also told me that he doesn't want to be too familiar with the project, so that he gets a better review of it when he does the inspections.

This makes a lot of sense to me - if someone is very familiar with a specific project, and often involved, it would be a lot harder to check well.

For me, I've been happy that they are available to me.

-Howard
 
MDRA woes

I didn't build, but my Dad built 2x, back in the TC inspector days, when Bob B. would come to your house on a Sat. & have lunch with you, and give lots of sage advise while praising your work ( if deserved).
Now following a neighbour building a -7, over the typical course of a 3-5 year build, out here in the BC interior, he's rarely gotten the same inspector twice, and has delayed the project waiting for inspections. ; "find an inspector you like" isn't an option, so I feel for builders in this quandry.
......this is where I guess we are supposed to feel lucky to be able to build at all!
While all this airing of problems is healthy, heaven forbid the feds decide to 'improve and overhaul' the MD-RA system! I, for one, rue the day.
 
Just a note for everyone : my inspector told me I could cover the shop head of the rivet with pro-seal in the tank. I was wondering then : what is he going to inspect?

I asked him and was told that he wanted to see inside. I mean, what does he want to see? The vent line? My first guess was that he wanted to look at the fuel pickup but I just realized that it's on the cover plate. If I had bought quick-built tanks, he would not get access.

Well, this is my first "problem" with MD-RA. The inspection on the empennage went well. I guess I'll leave the baffle off for now. Not that I really mind working on something else than my tank now!
 
seems hardly a problem

I think he's doing you a favour and accomodating a builder who wants to install the tank rivets "wet". That is what I did, and the inspector simply noted that he was unable to inspect those rivets - wasn't a problem.
But something that one would want to check with the inspector before proceeding - another example where consistency would be helpful, but if you asked for an "official" position, who knows what the answer would be.
As others have said, best to focus on building, and come to whatever understanding you can with the fellow who will be doing the inspection, if that is possible.
Bill Brooks
Ottawa, Canada
RV-6A finishing kit
 
C-GRVT said:
I think he's doing you a favour and accomodating a builder who wants to install the tank rivets "wet".
Click to expand...

Yep, I got that. What I did not get is why can't I put the baffles on if you can't look at the rivet? You can't even see if the parts are installed with a tight fit : the filet around the ribs hides the imperfections.

But you're right, the best is to ask. The problem is that I know for a fact that I have the same inspector as the guy prkaye is referring to... If he does not want me to close up the tail, I'll just leave the wings unclosed and start the fuselage. When I'm ready to close the top, I'll have the inspector inspect both the wings and the fuselage. Then, couple of months (years?) later, I'll do my final inspection.
 
that is what I did

Empennage, wings, tanks, fuselage, all were inspected in one "precover" inspection. I left one side of each structure clecoed, except for the flaps, which can be inspected through the spar lightening holes. On the fuselage, the inspector wanted to be able to see behind the vertical covers on the F-604 bulkhead -once these were inspected, they could be blind riveted in. Floors of course have to be left open as well for the precover inspection. Next inspection will be the final.
Bill Brooks
Ottawa, Canada
RV-6A finishing kit
 
MDRA

Bill, this exactly what I did. No issues, no snags.
Only the final inspection to follow. I've installed
"Canadian" dual gascolators which are mounted in
lowest point of the wing roots. My inspector was
impressed with the quality of the QB .
 
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Not sure if anyone has the answer to this...

Im in the process of importing an airplane to Canada (amateur built)

and I found a bit of a difference between the MD-RA checklist and CAR 549 standards.

The checklist says you need to be able to open the canopy/door from the outside. however I cant find this anywhere in the regulations from TC..

Anyone have any thoughts?
 
Import

hi, wish i could answer that question for you. i'm subscribed to follow the answers as they come in!
what type are you importing?
 
Well folks,

After nearly 4 months of farting around with the "MDRA" "professionals" I finally have my paperwork.

My mother always told me if I dont have anything good to say, dont say anything at all.... so here I am saying nothing, except for I will be submitting a CAIRS for the whole ordeal.



If anyone wants specifics, pm me.

-Tom
 
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