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I used to fly with a guy who had it down to a science. Flying? No. Through extensive research, he had narrowed it down to when the FAA Aviation Safety Inspectors (ASI) were most likely to conduct a Part 91 ramp check. His research concluded that it all came down to Wednesday after lunch.
Ben Stauffer is an attorney based in Orange, CA and is licensed to practice law in California and Nevada. While participating as a panel attorney for AOPA’s Legal Services Plan from 2009 until April 2019, Mr. Stauffer assisted numerous members with FAA enforcement matters, accidents and incidents, as well as aircraft purchase/sale transactions. He is an instrument rated commercial pilot and has been flying for over 25 years including six years in narcotics interdiction.
Does his conclusion suggest that all ramp checks are most likely to happen on a Wednesday after lunch? Of course not, but as chance would have it, one Wednesday afternoon we were flying together over the Los Angeles basin and headed to a great airport restaurant for lunch. As we flew overhead and started our descent to land, he noticed a white Crown Victoria parked in the transient airplane parking area near the runway. This coupled with the time of day led him to believe that a dastardly FAA inspector was down there waiting to conduct a ramp check on the next hapless pilot to land. He actually contemplated going somewhere else to eat, but I talked him out of it. We landed and taxied toward the transient parking area and were relieved to find out it was one of our friends waiting to meet us for lunch.
Although ramp checks rarely occur, what if you were not so lucky and that white Crown Victoria turned out to be a ramp check waiting to happen courtesy of your local ASI or law enforcement officer (yes, they can also conduct a ramp check)? After all, what kind of questions would the ASI ask, and what guidelines do they follow? Some insight can be found here in FAA Order 8900.1, which contains guidance to inspectors on how to conduct a Part 91 ramp inspection.
Make no mistake, well-intentioned pilots have been known to get flustered during a routine ramp check and share too much information with the ASI because they were unfamiliar with the procedures. To complicate matters, some pilots don’t realize the information provided to the ASI could be used against them in any future FAA enforcement actions.
You might be wondering what prompts ramp checks in the first place. According to FAA Order 8900.1, the most common reasons for a ramp inspection include:
No matter the reason for a ramp check, pilots will want to know the following suggested “Dos and Don’ts” so you’re better prepared in case it happens to you.
1. Do - Be Polite and Respectful – “you catch more flies with honey than vinegar”
The ASIs have a job to do. They are performing a safety function that is important, albeit uncomfortable for some pilots they contact. There is a lot of discretion afforded to ASIs and law enforcement to determine the outcome of any minor issues found. Upsetting them will not help the outcome of your ramp check.
2. Do - Identify
Whether an ASI or law enforcement is conducting your ramp check, they should have proper identification and should present it to you. If they do not, ask to see it before starting the ramp check. Write down the name and employee number of the person doing the ramp check.
3. Do - Take a Friend
If you have a friend with you, have them remain as a witness. Witness means they listen and watch, not talk. If you know your friend cannot comply with #1, ask them to go wait in the terminal/FBO.
4. Do - Have All Paperwork in Order
You are required to have the following in your possession/in the aircraft for inspection (as applicable to your flight): your airman and medical certificates, radio operator’s license (if you have one), picture identification, aircraft airworthiness certificate, registration certificate, operating manual, and weight and balance sheet. Make sure they are all current for the operation you are conducting.
5. Do - Follow-Up
If there was a discrepancy found that was not deliberate or intentional and your ramp check was not after an accident occurred, submit a NASA Aviation Safety Report within 10 days of the ramp check. There is no limit on how many reports you can file, and it may serve as a key piece of support if there is a letter of investigation issued as a result of your ramp check for a minor violation.
1. Don’t - Carry Unnecessary Paperwork
Unless required to conduct the flight, you should not regularly carry your pilot or aircraft logbooks in the airplane because they could get damaged or lost. Regardless of where you keep your logbooks, they are always subject to inspection upon reasonable request under FAR 61.51(i)(1).
2. Don’t - Discuss Past Flights
Including the flight you may have just completed, don’t discuss the details of previous flights. When the FAA questions you about past actions, that is what we call an investigation. Especially if the ASI presented the Pilots Bill of Rights notice before the ramp check began, do not discuss past flights. Be respectful but advise the official that you have been instructed to not discuss such matters until you are first able to consult with your attorney. By the way, this is also true for responding to any of those requests to call ATC after you land. Just secure your aircraft and do not call ATC without first contacting your attorney.
3. Don’t - Consent to the FAA Entering/Searching the Aircraft
Unless conducting commercial operations (which follow a different set of ramp check guidelines) the ASI does not have the right to enter the airplane. They do have the right to inspect the interior from the outside, but that can be quite difficult for them to do if you have sun shades in the windows. Be polite (see Do #1) but explain that you have been advised not to consent to them entering the aircraft. Once inside, items observed to be out of compliance can be included in any action the FAA may take against you.
4. Don’t - Offer Additional Information/Documents
Be careful offering to show your electronic flight bag software or any pre-flight documents you may have on board. While this may seem like simple cooperation and fostering a good relationship, it can lead to allegations of improper or insufficient pre-flight planning if they see an error or omission in your planning, especially if what they see only represents part of your pre-flight preparations.
5. Don’t - Cut Short Your Shutdown Procedures
It can be distracting when you see an FAA ASI approaching for a ramp check after landing. Be sure to follow your procedures and shut down the aircraft according to your normal checklist. Secure the flight surfaces and aircraft as you would for any other flight, including wheel chocks and/or tying down. These are all things you should finish before starting any discussion with the FAA about your aircraft to ensure you don’t leave your battery on or leave the plane in an unsafe condition that the FAA may later point out as an issue.
Fly safe and never put yourself in a position where you feel the need to avoid a ramp check at all costs! Be prepared so you will not have any issues if you are selected for a ramp check… no matter how rare they might be.