Camera & Equipment M
I am concerned by what seems to be a lack of awareness of the requirements when fitting cameras and tablet computer holders to an aircraft, particularly within GA. It appears that, just because pilots/owners are able to buy these mounts, both suction cups and self-adhesive, then they are permitted to fit them to their aircraft. Only on two occasions have pilots approached me to ask if there is a specific requirement to follow to have such mounts installed, and were totally unaware that there are CAA documents that regulate such installations.
CAP 1369 and [CS-STAN] Standard Changes CS-SC104 and CS-SC105 give clear instructions yet pilots seem to be unaware of their existence or are just ignored. A brief search on YouTube will show an abundance of pilots sharing videos of their flights online, many of which have tablets mounted to the yoke or suction cups holders on the windows and canopies, with no secondary lanyards and in positions likely to cause a problem should they become detached. I’m raising this in the hope that pilot / owners will be made aware that there are rules to be followed when installing these mounts.
CAP1369 ‘Policy and guidance on mounting cameras on aircraft’ was withdrawn on 10 May 2022 following CHIRP’s engagement with the CAA. The section that had referred to internal mounting of cameras (Page 5) had only addressed small camera installations mounted internally or externally on aircraft structures that were self-contained, (i.e. with internal batteries and no external wiring), such as GoPro and similar size cameras that are of small form-factor and relatively light, (<250 g including mountings). Such installations would be expected to have low or negligible effect at the aircraft level with regard to mass, centre of gravity, structural strength and drag and would thus be expected to have no appreciable effect on aircraft systems, handling or performance. CAP1369 Page 5 went on to highlight that risks to the aircraft and its occupants (as well as third party risks posed by the installation including potential camera and mount detachment), need to be managed and mitigated by careful installation and assessed by the LAE for acceptability and documented accordingly. At Pages 8-12, CAP1369 included an LAE installation checklist for use of electronic equipment that specified, inter alia: Checklist Item 7: If suction mounts are used inside the cockpit or cabin, a suitable secondary retaining lanyard or strap should be attached to the mounting to prevent damage or a control jam should the primary suction mount become detached. Checklist Item 11: If the camera is fitted in or near the cockpit, it must not interfere with any cockpit controls, nor obstruct the pilot’s view of instruments, the pilot’s external view or cause a distraction, (the flash window / gun should be taped over). Checklist Item 13: Push/Pull test requirement – the camera and its attachment mountings should be weighed prior to installation and checked to ensure that the total weight does not exceed 250g. In order to check the security under flight, ground and emergency landing cases, a spring balance or other suitable method should be used to apply separate loads to the mounted camera of at least: 9 times the weight forwards; 4.5 times the weight up; 6 times the weight down; 3 times the weight port; 3 times the weight starboard. The CAA commented that CAP1369 had been withdrawn due to its content now being covered in other areas of the CAA website in general terms and also within CS-STAN. The CAA will review the CAP in the future, although they were unable to provide any timescale. In its place, the CAA website now informs the user that “for certified aircraft the method for approval is included in [CAA] CS-STAN - Standard Change CS-SC105a (Installation of mounting systems to hold equipment). For type accepted aircraft overseen by the British Microlight Aircraft Association or Light Aircraft Association those organisation’s requirements apply”. Note that the CAA UK document referred to in the link above is the old EASA CS-STAN document Issue 3. EASA have since updated their document to Issue 4, which contains the same information in this respect but re-paragraphed as CS-SC105b, not as CS-SC105a. EASA CS-STAN Issue 4 section CS-SC105b ‘INSTALLATION OF MOUNTING SYSTEMS TO HOLD EQUIPMENT’ states, inter alia: · If the unit is fitted in or near the cockpit, it must not interfere with any cockpit controls, nor obstruct the pilot’s view of the instruments, or the pilot’s external view, and it must not cause a distraction to the pilot. · The mounting system must be installed on one of the fixed surfaces of the aircraft, i.e. not on any control system components that are subject to motion. There must be no interference with the flight controls. · Where brackets, clamps and/or attachments are used, care must be taken to ensure that they do not damage the aircraft structure that carries flight loads. · If suction mounts are used inside the cockpit or cabin, a suitable secondary retaining lanyard or strap should be attached to the unit to prevent any damage or a control jam if the primary suction mount becomes detached. · For suction mountings, the primary suction mounting and secondary lanyard/strap should be assessed so that each is independently capable of carrying the load of the equipment. · Push/Pull test requirement: the equipment should be weighed prior to installation and checked to ensure that the total unit mass does not exceed 300g. Installers are advised to record the mass of the mounting system in a visible area. · In order to check the security of the mounting system in flight, ground and emergency landing cases, a spring balance or another suitable method should be used to independently apply loads to the mounted unit of at least: 9 times the weight of the unit forwards; 4.5 times the weight of the unit upwards; 6 times the weight of the unit downwards; 3 times the weight of the unit to port; 3 times the weight of the unit to starboard. Loading should be applied for at least 3 seconds with no failures, damage or permanent deformation. Higher load factors should be considered appropriate for aerobatic use and should include a downwards case of 9 times the weight of the unit. · When a suction mount is used, pull testing should be used to confirm the integrity of the secondary retention to at least 10 times the weight of the unit. Periodic rechecking of the primary mount integrity is advised. Proprietary self-adhesive mounts can be used in accordance with the manufacturer instructions provided that they are capable of passing the pull tests. The installation of a secondary independent lanyard/strap retention feature may also be considered prudent when using these types of mounts. There are some great cameras and equipment available these days that are small and self-contained and which can provide an important addition to safety and instructional efficiency because they give valuable insights and factual evidence as to what was going on both in the cockpit and externally. However, although the carriage of some electronic equipment in the cockpit can be very beneficial, care must be taken to ensure that appropriate risk assessments are made so that any mountings are carefully considered to ensure they are secure and safe. Also, as we said previously in GA FEEDBACK Ed84, the use of recording devices that could be a distraction should be avoided, and pilots should also avoid providing a running commentary to any recoding equipment because this can sap mental capacity and distract from the conduct of the flight. These days we’re so used to simply attaching such equipment to car windscreens etc that we can sometimes forget about the unique requirements that come with their use in aircraft. The key things to think about are that they must not interfere with any cockpit controls; not obstruct the pilot’s view of the instruments (or the pilot’s external view); must not cause a distraction to the pilot; and a Push/Pull test should be carried out to make sure the item is secure when installed (see the CAA/EASA CS-STAN references for advice on suitable test loading). Also, if suction mounts are used inside the cockpit or cabin, a suitable secondary retaining lanyard or strap should be attached to the unit to prevent any damage or a control jam if the suction mount were to become detached. In that respect, it's also important to consider where and to what part of the aircraft the lanyard is attached; drilling holes randomly in the flight deck would effectively be an unapproved modification. Secondly, lanyard length should be based on restricting freedom of movement of the equipment were it to become “unstuck”, and not on the ease of attachment/detachment of the equipment in use. Equally important, lanyards (and any connecting cables and leads) can present their own problems if they’re at risk of fouling things or getting in the way, and so their positioning and length also require careful consideration in that respect. Finally, the implications of multi-installations that end up festooning the cockpit with equipment should also be carefully considered; ultimately we need to consider why we are putting things in the cockpit in the first place and limit them to those that are absolutely valuable to the flight’s purpose. The CAA reacted swiftly to CHIRP’s suggestion that the old CAP1369 was outdated by withdrawing it from use. However, many pilots were probably not even aware that CAP1369 existed, nor that specific permissions or certification of installation must be obtained in some cases. The issue of cockpit installation of electronic equipment therefore needs greater awareness, and CHIRP has suggested that the CAA could usefully include an article in relevant safety channels such as Clued-Up, SkyWise or ‘Safety Sense’, even if just to publicise the withdrawal of CAP1369 and point people towards the appropriate website links."