Javier Torre posted in Air Operations
Dear all,
I wanted to get your opinion on the following question:
1) Do you consider that navigation charts are required in critical phases of the flight? (take-off run, the take-off flight path, the final approach, the missed approach, the landing, including the landing roll)
2) Do you interpret that the EASA regulation requires it?
The context is the use of portable EFBs as a source for navigation charts. For the portable EFB to be used in all the critical phases of the flight, it requires a support/mounting device (ref to AMC1 CAT.GEN.MPA.141(a)).
I couldn't find any reference in the regulation requiring charts in critical phases of the flight, but the RIM (Ramp Inspection Manual) Appendix 1 asks SAFA inspectors to enforce it (refer to page 36, PDF Code = A03-14).
The regulation requires to keep the constrains and orders enclosed in the charts, not asking for the charts itself or physically (is my understanding). In several (smaler) cockpits an portable EFB is hindering and stowed anyway...
AMC1 SPA.EFB.100(b) says more about general placement of the EFBs...
Dear Javier!
Good point. My personal point of view is that you cannot compare that to every aircraft type. As Axel also mentioned, there are smaller cockpits sometimes.
Also considerable is the type of avionic you are using. Modern cockpits (G5000 for example) can display charts however you like it. Other thing are old cockpits (Honeywell for example) where additional devices are required. And there you face the problems you mentioned initially.
Sometimes NAA approve EFB Manuals but during SACA-checks non-compliances are raised on that topic.
A risk assessment – required by SPA.EFB.100 – should consider the type of aircraft you are operating and be the solid base for the procedures you want to apply.
My point of view is that you are full compliant with the regulation when the EFB as source of nav. charts is stowed during critical phases of flight.
AMC1 CAT.GEN.MPA.141(a) Use of electronic flight bags (EFBs) states:
"Portable EFBs may be used in all phases of the flight if secured to a certified mount or securely attached to a viewable stowage device in a manner that allows its use."
"Portable EFBs that do not meet the above characteristics should be stowed during critical phases of the flight.
However, this does not preclude a flight crew from using a portable EFB during restricted portions of the critical phases of flight to complete a task related to the safety of the flight on the condition that the device is continuously handheld and used only during a short period of time. When the task is completed, the device should be stowed again."
The last paragraph ist crucial in this particular question.
Dear all,
thank you for your replies! I agree with you all: I don't think the current regulation imposes it and I don't think it should for the reasons you mentioned.
However, we have a finding from a SAFA inspector for this specific point and it is written in the RIM (Ramp Inspection Manual) Appendix 1. I have reached out to EASA, I will keep you posted if I get a reply.
Javier, please keep us posted on the results, it sounds interesting, wondering if it's subject to interpretation from the inspector, or we are missing something here that might apply to other airlines. I agree with the others, as long as its accessible, it should be enough. When there are ramp findings, we find that requesting additional clarification from the inspector helps, if you have not done so, I would request it and put the reference above on how it is not mandatory, as long as its accessible, which based on your question, can i assume it is not stowed away in a section of the plane which the crew can only access once they are on the ground blocked in? Interesting topic, thank you for the question.
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