IS-BAO 8.14 – Flight Data Recorders and Cockpit Voice Recorders

In a recent post on the NBAA AirMail forum an operator questioned the discovery, during an IS-BAO audit, of the requirement for a flight data recorder (FDR) to be installed on their aircraft. The individual did not provide information, regarding aircraft type or age, so it is not possible to address the FDR requirements specifically for this operator.

 
What becomes evident is the IS-BAO Standard stays true to the ICAO SARPS…
 

To discover how an operator could be surprised by this requirement let’s take a look at each of the IS-BAO FDR/CVR requirements and how they relate to the ICAO and FAA requirements.  What becomes evident is the IS-BAO Standard stays true to the ICAO SARPS and bases the FDR/CVR requirements on aircraft weight, whereas the FARs deviate from the ICAO SARPS and base the FDR/CVR requirements on the number of passenger seats. Note that the FARs applicability dates also deviate from the ICAO SARPS.

IS-BAO 8.14.1
All aeroplanes for which the individual certificate of airworthiness was first issued on or after January 1, 1989 and that have a maximum certificated take-off mass over 27,000 kg (59,525 lbs), shall be equipped with a Type I flight data recorder.

ICAO Annex 6, Part 2, Section 3.6.3.3
Flight data recorders — aeroplanes for which the individual certificate of airworthiness is first issued on or after 1 January 1989

3.6.3.3.1
All aeroplanes of a maximum certificated take-off mass of over 27,000 kg shall be equipped with a Type I flight data recorder.

FAR 91.609(c)

(1)
No person may operate a U.S. civil registered, multiengine, turbine-powered airplane or rotorcraft having a passenger seating configuration, excluding any pilot seats of 10 or more that has been manufactured after October 11, 1991, unless it is equipped with one or more approved flight recorders that….

(2)
All airplanes subject to paragraph (c)(1) of this section that are manufactured before April 7, 2010, by April 7, 2012 [compliance date], must meet the requirements of §23.1459(a)(7) or §25.1459(a)(8) of this chapter, as applicable.

(3)
All airplanes and rotorcraft subject to paragraph (c)(1) of this section that are manufactured on or after April 7, 2010, must meet the flight data recorder requirements of §23.1459, §25.1459, §27.1459, or §29.1459 of this chapter, as applicable, and retain……

 

IS-BAO 8.14.2
All aeroplanes for which the individual certificate of airworthiness was first issued on or after January 1, 2005 that have a maximum certificated take-off mass of over 5,700 kg (12,567 lbs) shall be equipped with a Type IA flight data recorder.

ICAO Annex 6, Part 2, Section 3.6.3.4
Flight data recorders — aeroplanes for which the individual certificate of airworthiness is first issued after 1 January 2005

All aeroplanes of a maximum certificated take-off mass of over 5,700 kg shall be equipped with a Type IA flight data recorder. [Type IA flight data recorders are explained in Annex 6 Part II Section 3.6.3.1.8]

FAR 91.609 (c)

See (1)-(3) above.

 

IS-BAO 8.14.3
It is recommended that all aircraft for which the individual certificate of airworthiness was first issued on or after January 1, 1989 and that have a maximum certificated take-off mass over 5,700 kg should be equipped with a Type II flight data recorder.

ICAO Annex 6, Part 2, Section 3.6.3.3
Flight data recorders — aeroplanes for which the individual certificate of airworthiness is first issued on or after 1 January 1989

3.6.3.3.2
Recommendation — All aeroplanes of a maximum certificated take-off mass of over 5,700 kg up to and including 27,000 kg should be equipped with a Type II flight data recorder.

FAR 91.609 (c)

See (1)-(3) above.

 

IS-BAO 8.14.4
All aeroplanes for which the individual certificate of airworthiness was first issued on or after January 1, 1989 and that have a maximum take-off mass over 27,000 kg shall be equipped with a cockpit voice recorder.

ICAO Annex 6, Part 2, Section 3.6.3.5
Cockpit voice recorders — aeroplanes for which the individual certificate of airworthiness is first issued on or after 1 January 1987 [note applicability date] 

3.6.3.5.1
All aeroplanes of a maximum certificated take-off mass of over 27,000 kg shall be equipped with a cockpit voice recorder, the objective of which is the recording of the aural environment on the flight deck during flight time.

FAR 91.609(e)
Unless otherwise authorized by the Administrator, after October 11, 1991, no person may operate a U.S. civil registered multiengine, turbine-powered airplane or rotorcraft having a passenger seating configuration of six passengers or more and for which two pilots are required by type certification or operating rule unless it is equipped with an approved cockpit voice recorder that:

(1)
Is installed in compliance with §23.1457(a)(1) and (2), (b), (c), (d)(1)(i), (2) and (3), (e), (f), and (g); §25.1457(a)(1) and (2), (b), (c), (d)(1)(i), (2) and (3), (e), (f), and (g); §27.1457(a)(1) and (2), (b), (c), (d)(1)(i), (2) and (3), (e), (f), and (g); or §29.1457(a)(1) and (2), (b), (c), (d)(1)(i), (2) and (3), (e), (f), and (g) of this chapter, as applicable; and

 

IS-BAO 8.14.5
It is recommended that all aeroplanes that have a maximum certificated take-off mass of more than 5,700 kg, should be equipped with a cockpit voice recorder.

ICAO Annex 6, Part 2, 3.6.3.5
Cockpit voice recorders — aeroplanes for which the individual certificate of airworthiness is first issued on or after 1 January 1987

3.6.3.5.2
Recommendation — All aeroplanes of a maximum certificated take-off mass of over 5,700 kg up to and including 27,000 kg should be equipped with a cockpit voice recorder, the objective of which is the recording of the aural environment on the flight deck during flight time.

FAR 91.609(e)

See (e)(1) above.

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