Airworthiness Requirements

Effective date 20th February 2022

These requirements summarise but do not replace the requirements detailed elsewhere in regulation, by manufacturers and in BGA airworthiness publications.

Airworthy’ means that the glider conforms to the appropriate legal and technical requirements for safe flight.

Maintenance’ means any one or combination of the following activities: overhaul, repair, inspection, replacement, modification or defect rectification of an aircraft or component, with the exception of pre-flight inspection.

Contents:

  1. Non-Part 21 Aircraft
  2. Part-21 Aircraft
  3. BGA Inspectors
  4. Responsibilities
  5. BGA Support
  6. Important Detail for Owners and Pilots
  7. Pilot/Owner Maintenance
  8. Weight and Balance
  9. Daily Inspection
  10. Complex Maintenance Tasks
  11. Maintenance Records
  12. Aircraft Documents
  13. Important Information for Club Committees
  14. Audit
  15. Detailed Information

1. Non-Part 21 Aircraft

 Non-Part 21 aircraft are those of historic interest and those whose production was stopped before 1 January 1975. Non-Part 21 gliders are certified and maintained under the self-regulated BGA airworthiness system.

Non-Part 21 aeroplanes are certified and maintained under national arrangements as required by the UK ANO.

2. Part 21 Aircraft

Part 21 aircraft are certified and maintained under retained EU requirements. The maintenance requirements are defined under the part of the retained regulations known as ‘Part M Light’. Part M Light requirements apply to Part 21 sailplanes, tugs and motor gliders. The Part M Light requirements are reflected within the BGA’s airworthiness system.

3. BGA Inspectors

 BGA inspectors perform and certify maintenance and repairs to non-Part 21 gliders and Part 21 sailplanes and powered sailplanes, including TMGs, and aeroplanes. Where certifying Part 21 sailplanes, powered sailplanes including TMGs, and aeroplanes, BGA inspectors are required to hold a Part-66L maintenance licence with the relevant privileges.

Information about BGA inspector ratings is available in the BGA Airworthiness and Maintenance Procedures on the BGA website. BGA inspectors operate under the BGA’s airworthiness approvals and airworthiness exposition. For details, including how to become a BGA inspector, refer to the BGA website.

4. Responsibilities

 Owner

Whether operating a non-Part 21 or a Part 21 aircraft, aircraft owners are responsibility for the airworthiness of their aircraft. Owners should ensure they are familiar with the relevant requirements, the related maintenance programme, and the aircraft maintenance manual.

The owner is solely responsible for ‘maintenance management’. This includes ensuring airworthiness directives are complied with, that any life limited components or inspections are enforced before they run out of life, and that the aircraft is only operated in an airworthy condition. Failure to do this is likely to invalidate the aircraft insurance.

More detail about owner responsibilities is available here.

Note – depending on how a gliding club is structured, ‘the owner’ of a club aircraft may be the club chairman or the committee members collectively.

Pilot

The pilot is responsible for the satisfactory accomplishment of the pre-flight inspection.

Pre-flight inspection’ means the inspection carried out before flight to ensure that the aircraft is fit for the intended flight.

BGA Inspector

In carrying out maintenance and/or signing aircraft documentation including BGA airworthiness documentation, the BGA Inspector accepts personal responsibility for the associated task.

5. BGA Support

The BGA provides airworthiness support to owners of aircraft that are included within the BGA airworthiness system. The support ranges from strategic, for example influencing retained EU and UK regulation, through to direct advice, guidance and support to inspectors and owners maintaining aircraft in the field.

6.  Important Detail for Owners and Pilots

I own a non-Part 21 glider. What do I need to know?

Non-Part 21 gliders are to;

  • Hold a Certificate of Airworthiness (C of A) issued annually by the BGA (an AMP refers)
  • Comply with the maintenance programme. An annual inspection is a fundamental requirement
  • Only to be flown if maintained in an airworthy condition

Visiting, non-BGA non-Part 21 gliders should have a document equivalent to a BGA C of A. Details of the BGA approved procedures for non-Part 21 gliders can be found in the AMP.

I own a Part 21 glider. What do I need to know?

Part 21 gliders are to;

  • Display national registration markings. Refer to CAA publication CAP523 with additional guidance in the AMP.
  • Hold a Certificate of Airworthiness (CofA) or Restricted CofA or Permit to fly. Part 21 gliders are required to hold a Part 21 Certificate of Airworthiness (where there is still factory product support) or Restricted Certificate (where there is no longer factory product support) or a CAA permit to fly (usually for a new type of glider awaiting full certification). The C of A and restricted C of A are non-expiring once issued. The permit to fly has to be validated annually.
  • Hold an Airworthiness Review Certificate (ARC). A valid ARC is required for flight in an EASA aircraft. The ARC is a review of all legal documentation (apart from insurance) including log books, certificate of registration, C of A, GMP, radio licence, airworthiness directives, lifed items, latest flight manual revision, placards and a brief inspection of the glider. Note that only one day of annual maintenance validity remaining is required to issue an ARC. The ARC is valid for a year. For ARC renewal guidance refer to the AMP.
  • Comply with the Maintenance Programme requirements. All gliders operated within the BGA airworthiness system use a Self-Declared Maintenance Programme (SDMP) – see AMP for details. The SDMP includes an annual inspection. Maintenance is subject to ‘Certificate of release to service’ (CRS) through certification by an approved person. In date annual maintenance is required for flight.
  • Only to be flown if maintained in an airworthy condition.

I own an aeroplane. What do I need to know?

Aeroplanes are to;

  • Display national registration markings
  • Hold a Certificate of Airworthiness (CofA) or Restricted CofA or Permit to Fly as appropriate. The C of A and restricted C of A are non-expiring once issued. The permit to fly has to be validated annually. For aeroplane airworthiness procedures refer to the AMP.
  • Hold an Airworthiness Review Certificate (ARC), or if non-Part 21 hold a National ARC (a NARC). Not applicable to Permit to Fly
  • Comply with the Maintenance Programme requirements. Maintenance is subject to ‘Certificate of release to service’ (CRS) through certification by an approved
  • Only to be flown if maintained in an airworthy condition

7. Pilot/Owner Maintenance

Pilot/owners are permitted to carry out and certify certain maintenance tasks on their glider. Details are in the Airworthiness and Maintenance Procedures on the BGA member’s website. Note that a student pilot is not deemed to be a qualified pilot and cannot perform Pilot Owner Maintenance – in this case they must arrange a BGA inspector to oversee any work they do.

It is important that pilot/owners ensure they are competent and aware of the requirements including paperwork requirements before carrying out any maintenance task on their glider. If in doubt, seek qualified BGA guidance.

In many cases, the services of a qualified inspector are needed. Some BGA inspectors are busy professionals and will quite properly charge a commercial rate. It is up to individual owners and inspectors to consider what service is required and to make their own arrangements, commercial or otherwise.

8. Weight and Balance

It is critically important that an aircraft Centre of Gravity is kept within the laid down limits. Replacement equipment, repairs and other factors can cause the mass of an aircraft and/or its component parts to change over time.

Weighing an aircraft is not a simple task and requires calibrated weighing equipment. If in doubt, the advice of an inspector should be sought. Refer to the AMP’s.

Owners are encouraged to seek a copy of the weighing data/report from the inspector or engineer who carried out the weighing.

9. Daily Inspections

Aircraft continuing airworthiness and air operations rules identify that the pilot in command is responsible for the pre-flight inspection, and that this inspection must be carried out by the pilot or another qualified person. BGA Operational Regulations state that “All gliders operated from BGA club sites shall be inspected before flying on each day. Club gliders shall be inspected by club approved persons who must sign that the glider is serviceable before it is flown on that day”.

The requirement to pre-flight inspect aircraft (ie gliders and powered aeroplanes) at BGA clubs is normally achieved by carrying out a Daily Inspection (DI). A DI is a safety critical task. The club, as the operator, is responsible for qualifying and authorising its members to carry out DIs of its club aircraft. The pilots age, experience and training to carry out DIs should be taken into consideration.

Details of how to complete a DI are normally to be found in the Aircraft Flight Manual. The DI should be recorded and signed for in the DI book or equivalent.

All pilots are advised that a signed DI does not necessarily mean that at the time of launching the aircraft is fit for flight. A walk-around pre-flight inspection by the pilot in command immediately before flight is good aviation practice.

10. Complex Maintenance

‘Complex maintenance’ (a Part M Light definition) is subject to specific requirements. Before taking on for example a repair, or fabric recovering task, etc, inspectors should refer to the complex maintenance AMP to confirm whether or not the task is deemed to be complex and what specific procedure may be needed.

11. Maintenance Records

All maintenance, servicing, repairs, replacements and defect rectification must be recorded and certified with the appropriate certificate of release to service and these records form part of the aircraft maintenance records.

Maintenance records should be maintained and retained until at least 2 years after the aircraft has been destroyed or permanently retired from service. The aircraft records stay with the aircraft and the owner has a responsibility to transfer the records to the new owner when sold.

Inspectors have a responsibility to retain their own records for 3 years after the maintenance is completed.

Maintenance records include:

  • Scheduled & unscheduled maintenance worksheets and sign-off.
  • Defect rectification worksheets
  • Test results and records
  • Details of any special inspections
  • Compliance with airworthiness directives
  • Duplicate inspection record
  • Record of flying hours and engine operation (aircraft logbooks)
  • Release certificates for parts & materials
  • Details of modifications including supplemental type certificates

These records should be filed in a suitable folder and in ‘maintenance event’ date order and kept safe and secure from damage or unauthorised interference.

12. Aircraft Documents

It is recommended that the paper documents and certificates for each glider are filed, eg using transparent wallets in a folder. This will keep all the documents for a particular aircraft in one place and easy to reference when needed. The aircraft logbook(s) and maintenance programme should be kept in a suitable folder. Keeping aircraft documents safe is important – it should be noted that replacing documents and certificates can be an expensive and time-consuming task.

13. Information for Club Committees

Club fleets tend to be well utilised. They are usually operated and flown by some of the least experienced pilots and can lead hard lives. And in many cases, the gliders are old – K8’s, K13’s and Pawnees are common examples. Therefore, maintaining club fleets can be quite a challenge. And it’s not just about staying safe. In the event of an accident, one of the first things an insurer will check is whether the glider is compliant with all related requirements.

There are various roles involved in properly maintaining aircraft:

The Owner

This would normally be the Chairman of the club or, collectively the Committee of Management. The ‘Owner’ is responsible for ensuring that the aircraft is properly maintained and operated. If the aircraft is leased, the owner’s/operator’s responsibilities should be laid out in the leasing agreement. If the aircraft is privately owned and loaned to the club the responsibility remains with the owner, but the club should verify everything is in order to satisfy their duty of care.

The Maintenance Manager

A suitable club member should be appointed by the owner to monitor and manage the ongoing airworthiness of the club’s gliders (a maintenance manager). The person who manages the maintenance of a Part 21 aircraft should be separate from the ARC process. The maintenance manager could be the club Technical Officer (or Aircraft Member/Technical Manager) depending on how a club is structured and the positions within the club. The Maintenance Manager carries out the maintenance management function. There are no formal qualifications required for this role, but an owner could be asked during audit to demonstrate who is fulfilling this task.

A suitable system should be established within the club for reporting and managing defects, as well as ensuring that AD’s, lifed items and on condition parts are addressed between ARCs and annual maintenance.

Those pilot members permitted to carry out pilot-owner maintenance on the club fleet should be listed by the club.

The Airworthiness Certificate or Permit to Fly, annual maintenance and insurance validity periods should be made available to everyone who uses the club fleet. A suitable placard is one way of addressing that. Another is to make sure copies of the documents are easily to hand.

It should be made clear to all club pilots who operate the aircraft whether any maintenance is outstanding, or any defects exist that affect the airworthiness of a club aircraft.

There are several ways of achieving that including documentation, cockpit warning signs, restricting access to the aircraft, etc.

When planning maintenance, the following points may need to be considered:

  • When are the aircraft needed?
  • What maintenance is required?
  • Who is doing the maintenance and their availability?
  • Workshop space and availability
  • Arranging for a third party to maintain the aircraft
  • Parts and materials
  • Cost and budget constraints

The Inspector. The inspector is the person who actually certifies the maintenance and repairs to the aircraft (other than pilot/owner maintenance).

14. Audit

An important responsibility for any airworthiness organisation is to carry out quality and oversight audits of aircraft within its responsibility. To achieve this, the BGA has a quality team including a Quality Manger and Quality Assistants. The Chief Technical Officer and Regional Technical Officers are there to offer guidance and support to clubs where needed.

Club or private owners may be selected as part of a structured audit plan for an oversight visit or, as the need arises, an unscheduled visit. Please allow access, provide assistance and make the aircraft and its records reasonably available for audit.

The CAA also has a responsibility (as part of their oversight of the BGA) to carry out audits. The CAA can carry out formal site audits and Aircraft Continued Airworthiness Monitoring (ACAM) audits.

These are selected randomly and if a club aircraft is selected, the owner has a legal responsibility to make available the aircraft and its records, including log books, maintenance records and certificates as requested at the agreed time and place. The ‘owner’ need not be present, but a representative must be.

An audit can result in a ‘Non-Compliance Notice’ containing findings, which must not be ignored. Findings are classified as either Level 1 or Level 2.

  • Level 1 findings must generally be answered before next
  • Level 2 findings usually have a limited response time depending on the occurrence

If a club has any difficulties the BGA CTO and RTOs are there to offer guidance. If an owner does not agree with any finding or does not understand it, they should refer to the originator for clarification.

15. Detailed Information

Detailed information is available via the BGA website airworthiness and maintenance webpages.

Details of BGA inspectors in a local area can be obtained from the BGA office.

End.