Civil Aviation Order 20.2 - Air service operations - Safety precautions before flight (02/12/2004)

CAO 20.2 uses several recurring concepts that are not defined within the order itself but derive from the CAR 1988 and the broader aviation regulatory framework.

“Pilot in command” is the person who, under the CAR 1988, has the final authority and responsibility for the operation and safety of the flight. Every duty in CAO 20.2 is imposed either on the pilot in command alone or jointly with the operator. The order assumes a single pilot in command, even for multi‑crew operations; the co‑pilot may perform some actions (such as removing locks or acknowledging removal) but always under the pilot in command’s direction.

“Operator” is not defined in the order but, by context, refers to the person or organisation that holds the air operator’s certificate or otherwise conducts the air service. The operator shares duties for fuel system inspections (paragraphs 5.1, 5.2, 5.3) and for ensuring the operations manual contains fuel‑quantity verification procedures (paragraph 6.1). In practice, the operator may delegate execution to the pilot in command or ground crew, but the order treats the operator as jointly liable - a point that can create tension in charter or aerial‑work operations where the operator is not the pilot.

“External control surface locks, undercarriage pins and locks, or other external locking or restricting devices” are the physical hardware used to prevent control surfaces from moving when the aircraft is parked or towed. The term “other external locking or restricting devices” is deliberately broad, covering any object - including gust locks, aileron pins, rudder locks, and similar items - that is fitted externally to restrict control movement. It does not cover internal cockpit restraints such as seat‑belt type harnesses.

“Solo flight” appears only in section 4. The order does not define “solo” but, by context, it means a flight where the pilot in command is the sole occupant or where no other person is in a position to operate the controls. The precaution extends to any dual‑control aircraft flown solo, not just training aircraft.

“Hot refuelling” is not defined in CAO 20.2. Reference is made to sections 20.10 and 20.10.1 of the CAO series, which presumably set out the conditions under which refuelling may occur while an engine is running or auxiliary power is active. The exemption in paragraph 5.1A applies only when the refuelling is conducted in accordance with those sections; any deviation restores the full inspection obligation.

“Fuel system” includes tanks, lines, filters, collector boxes, and vents. The inspection requirement in paragraph 5.1 covers the entire system, not just the tanks. The note to paragraph 5.1 emphasises that sensory checks of colour and smell are unreliable; acceptable methods include the “visible surface of demarcation” technique, chemical water‑detecting paper or paste, and, for turbine fuel, inspection for persistent cloudiness. The note also recommends a stagnation period for turbine fuel before sampling, acknowledging that water settles more slowly in Jet A1 than in avgas.

“Maximum take‑off weight” appears only in paragraph 6.1, which applies to aircraft over 5,700 kg engaged in commercial operations. That weight threshold corresponds to the definition of “large aircraft” in some regulatory contexts, but the order does not explicitly import that definition. The threshold creates a bright‑line regulatory burden: aircraft just under 5,700 kg are exempt from the fuel‑quantity verification procedure, even though fuel mismanagement is a leading cause of accidents in smaller aircraft as well.

The order also relies on the concept of an “approved method” for water detection, but does not specify which methods are approved. The note to paragraph 5.1 lists three acceptable methods, but the word “approved” in the text likely refers to approval by CASA or under the maintenance regulations. In practice, most operators treat the note as the definitive list.

CAO 20.2 imposes duties on two main categories of persons: the pilot in command and the operator. A third category - ground staff or third parties instructed to remove locking devices - is referenced but not directly regulated; their obligations arise only from the contractual or operational directions given to them.

Pilots in command are the primary duty‑holders. Every section (2, 3, 4, 5, 6) places at least one obligation directly on the pilot. The pilot must: ensure external locks are removed before taxiing (paragraph 2.2); not commence taxiing unless a specific confirmation process has been completed (paragraph 2.3A); inspect control systems after high‑wind events (paragraph 2.4); test flight controls to full travel before taxiing (paragraph 2.5); secure all doors and hatches (section 3); secure harnesses and detachable controls before solo flight (section 4); ensure fuel system inspections and tests are performed (paragraph 5.1); and, for larger commercial aircraft, verify fuel quantity using the operations manual procedures (paragraph 6.1). The pilot is not required personally to perform every physical action - a co‑pilot or ground staff may remove locks or drain fuel samples - but the pilot retains ultimate responsibility. Failure by a delegate to act properly remains the pilot’s breach.

Operators share duties for fuel system inspections and tests (paragraphs 5.1, 5.2, 5.3) and for fuel‑quantity verification procedures (paragraph 6.1). The operator must ensure the operations manual contains appropriate instructions, and must ensure that inspections for water contamination are performed before each day’s flying and after each refuelling. The operator also bears the obligation under paragraph 5.1A to ensure that hot refuelling is conducted in accordance with the relevant CAO sections. In practice, the operator will usually delegate performance to pilots or maintenance staff, but the order does not permit delegation of legal liability. An operator who fails to create a system that ensures compliance faces enforcement action directly.

Co‑pilots are mentioned in paragraphs 2.2, 2.3.2, 2.3.4, and 2.3A. They are permitted to remove locks and are included in the exhibition and acknowledgement process. Under paragraph 2.3A, the co‑pilot’s confirmation that a lock has been removed provides a basis for the pilot in command to begin taxiing even if the lock was not exhibited to the pilot in command. This is a limited safe harbour for the pilot, but it does not absolve the co‑pilot of any duty under other regulations.

Maintenance engineers are referenced in paragraph 2.4: where an aircraft has been exposed to high winds (exceeding 35 knots) and the controls were not effectively restrained, “the pilot in command or an appropriately licensed maintenance engineer” must inspect control systems and attachments before flight. This is the only provision that grants a maintenance engineer an independent role; in all other circumstances, the order assumes the pilot or operator is responsible.

Third‑party removers - persons instructed to remove locking devices - are subject to the process in paragraph 2.3. They must act only as directed by the pilot, must exhibit the removed items, and, at night, must have adequate lighting provided by the owner, hirer, or operator. They are not directly penalised under the order (that would require another source of law), but the pilot’s liability depends on their compliance.

Owners and hirers are mentioned in paragraph 2.2 and 2.3.3 as persons who may authorise a person to remove locks, and who must ensure adequate lighting at night for exhibition. Their role is limited; the order does not impose ongoing duties on owners or hirers beyond those specific provisions.

The order affects virtually every Australian‑registered aircraft engaged in air service operations - including charter, aerial work, and commercial transport - as well as private operations if they fall within the regulatory scope of CAR 1988. The weight threshold in paragraph 6.1 excludes lighter aircraft from fuel‑quantity verification, but all other provisions apply regardless of size.

The order imposes a series of discrete, chronological duties that must be performed before certain flight events. There are no rights conferred on individuals - the order is purely regulatory, granting no cause of action to passengers or third parties. The duties are as follows.

Removal of locking devices (sections 2 and 3). The core duty is in paragraph 2.2: external control surface locks, undercarriage pins and locks, and other external restricting devices must be removed before taxiing for take‑off, except where CASA approves otherwise. Removal must be performed only by the pilot in command, co‑pilot, or a person instructed and authorised by the owner, hirer, operator, or pilot. If a non‑flight‑crew person removes the devices, a verification chain must be followed: removal must be directed by the pilot; the items must be exhibited to the pilot or co‑pilot from a position that allows clear determination that all items are displayed; at night, adequate lighting must be provided; and the pilot or co‑pilot must give an agreed form of acknowledgement (paragraph 2.3). Paragraph 2.3A adds a further duty: the pilot in command must not start taxiing for take‑off unless the co‑pilot has confirmed that any lock removed by a person other than the pilot has been exhibited, or that the co‑pilot removed it themselves. This is a two‑stage safeguard.

Post‑high‑wind inspection (paragraph 2.4). If the aircraft has been parked, taxied, or towed in winds exceeding 35 knots and the control systems were not effectively restrained (either by a person in the cockpit or by approved gust locks), the pilot or a licensed maintenance engineer must inspect control systems and attachments for damage before flight. The duty is triggered by the fact of wind exposure, not by observed damage.

Pre‑taxi flight control test (paragraph 2.5). Immediately before taxiing for take‑off, the pilot must test the flight controls to the full limit of their travel and make any other necessary tests to ensure correct function. This duty repeats and amplifies the requirement in paragraph 244(1)(a) of CAR 1988. If external locks have been removed or if maintenance work has been performed on control surfaces or systems, the duty arises even if the pilot would otherwise test controls later. The note to paragraph 2.5 reminds the reader of the CAR 1988 requirement, but the CAO duty is independent.

Security of doors and hatches (section 3). “Immediately before taxiing for the purpose of taking off”, the pilot must ensure all doors, escape hatches, and loading hatches are properly secured. This includes cargo doors, passenger doors, and emergency exits. The duty is unconditional; there is no exception for aircraft with known non‑securing door hardware.

Solo flight precautions (section 4). For an aircraft fitted with dual controls that is to be flown solo, the pilot must ensure safety harnesses and any other articles or equipment that might foul the controls are safely secured. If the second control column is readily detachable, it must be removed. The duty is triggered when the aircraft is “to be flown solo” - which includes any flight where the pilot is the only person on board, even if the aircraft would normally carry two crew.

Fuel system water inspection (section 5). Paragraph 5.1 imposes a joint duty on the operator and pilot. They must ensure inspections and tests for water in the fuel system are made in accordance with either (i) approved manufacturer’s data (if such data exists and is approved under regulation 42M of CAR 1988), or (ii) in any other case, before the start of each day’s flying and after each refuelling, by draining a small quantity from each tank into a clear transparent container and checking by an approved method for water. A sub‑duty applies to aircraft types specified by CASA: the inspection must extend to filters and collector boxes. The note recommends that all aircraft types perform that extended inspection at frequent intervals, but only CASA‑specified types are compelled.

Paragraph 5.1A creates a limited exception: for hot refuelling conducted under sections 20.10 or 20.10.1, the post‑refuelling inspection is not required. However, the daily pre‑flight inspection is still mandatory. The operator bears the duty to ensure the hot refuelling complies with the relevant CAO.

Paragraph 5.2 requires that if a significant quantity of water is found, the operator and pilot must ensure all traces are removed, including from filters, before further flight. The note warns that water may lie in inaccessible parts of the system due to aircraft attitude or design. Paragraph 5.3 requires that before each day’s flying, all external fuel tank vents be inspected for freedom from obstruction.

Fuel quantity verification (section 6). For an aircraft with a maximum take‑off weight over 5,700 kg engaged in commercial operations, the operator must ensure that the operations manual contains instructions and procedures for the pilot to verify fuel quantity before flight. The order does not prescribe the content of those procedures; it refers instead to an Airworthiness Bulletin (28‑002) for advisory guidance. The duty is on the operator to create the system; the pilot then uses it. Failure by the operator to maintain the manual means the pilot may have no legally sufficient procedure to follow, which could itself constitute a breach of paragraph 6.1 by the operator.

CAO 20.2 itself does not prescribe penalties. It is made under subregulation 244(2) of the CAR 1988, and enforcement flows from the parent regulation. The CAR 1988, at the time of this compilation, provided that a contravention of a Civil Aviation Order is an offence. Specifically, regulation 313 of CAR 1988 generally makes it an offence for a person to contravene a provision of the regulations, and a breach of a CAO is a breach of a regulation. The maximum penalty for an individual was, at the relevant time, 50 penalty units (or imprisonment for a first offence, depending on the specific subregulation). For a corporation, the penalty could be higher under general principles of corporate criminal liability.

Practically, the main enforcement mechanism is CASA’s power to: suspend or cancel an air operator’s certificate or a pilot’s licence; issue infringement notices (on‑the‑spot fines); and prosecute breaches through the Commonwealth Director of Public Prosecutions. CASA also has powers under the Civil Aviation Act 1988 to issue directions, impose conditions, and seek injunctions.

The most serious breaches under CAO 20.2 are likely failures to remove locking devices (section 2) and failures to detect water contamination (section 5). A control surface lock left in place can cause loss of control on take‑off, potentially leading to a fatal accident. Water in the fuel can cause engine failure. A pilot who commences taxiing without completing the removal process under paragraph 2.3A commits a breach regardless of whether any lock actually remains. Similarly, an operator who fails to ensure the daily fuel inspection is performed breaches paragraph 5.1 even if no water is present.

The order does not contain a defence of due diligence or reasonable reliance. If a pilot instructs a ground staff member to remove locks and the ground staff member fails to remove one, the pilot is still in breach of paragraph 2.2 for not ensuring removal. The only partial safe harbour is in paragraph 2.3A(d): if the co‑pilot confirms the removal, the pilot may taxi. But if the co‑pilot is mistaken, the pilot still commences taxiing with a lock in place - the order does not provide immunity.

Enforcement can also be indirect. Under paragraph 2.5, the pilot must test flight controls before taxiing; if a lock blocks full travel, the test should reveal it. A pilot who taxies without performing the test, even if no lock is present, has breached paragraph 2.5. CASA could prosecute that breach separately.

The practical enforcement risk for most operators is low - CASA cannot inspect every pre‑flight - but the consequences of an incident are severe. In the event of an accident, the investigation will examine compliance with CAO 20.2, and any breach may be used to establish negligence, potentially voiding insurance coverage or leading to criminal charges.

CAO 20.2 sits within a hierarchy of aviation legislation. Its direct parent is subregulation 244(2) of the CAR 1988. Regulation 244(1) already imposes a duty to test flight controls immediately before take‑off; sections 2.5 and 5 of CAO 20.2 supplement that duty with more specific and earlier timing - “immediately before taxiing” rather than “immediately before taking‑off”. A pilot who complies with CAO 20.2 sections 2.5 and 5 will probably also satisfy regulation 244(1)(a), but the converse is not guaranteed. A pilot who tests controls only at the runway holding point would breach CAO 20.2 paragraph 2.5 if they had already taxied away from the parking bay.

CAO 20.2 interacts with other Civil Aviation Orders. Section 5.1A explicitly cross‑references CAO 20.10 and CAO 20.10.1 (hot refuelling orders), exempting post‑refuelling water checks only if the refuelling complies with those orders. If an operator hot‑refuels in a manner that does not satisfy the conditions of those orders, the exemption disappears, and a failure to perform the water check after that refuelling is a breach. The cross‑reference places a duty on the operator and pilot to know the requirements of the other orders.

CAO 20.2 also interacts with the maintenance regulations. Paragraph 5.1(a)(i) allows use of approved manufacturer’s maintenance data (approved under regulation 42M of CAR 1988) as an alternative to the standard daily drainage procedure. Where an aircraft has an approved maintenance schedule that includes fuel system water checks at different intervals, the operator may follow that schedule instead. However, the order does not allow the manufacturer’s data to reduce the daily check requirement unless the data itself specifies an alternative frequency. In practice, most aircraft maintenance schedules require a daily or pre‑flight check anyway.

The fuel‑quantity verification requirement in paragraph 6.1 ties into the Airworthiness Bulletin 28‑002, which is advisory but not legally binding. A court or tribunal would likely consider compliance with the bulletin as evidence of reasonable steps, but failure to follow it does not automatically constitute a breach if the operations manual contains substantively equivalent procedures.

The order must be read together with Part 5 of the Civil Aviation Safety Regulations 1998 (CASR 1998), once those regulations replaced CAR 1988 for certain aircraft. However, the compilation date is 2006, when CAR 1988 was still the governing instrument for many operations. CASR 1998 Part 91 (General operating and flight rules) now contains equivalent provisions, but the order remains in force for aircraft still operating under the old regulations. A pilot operating under CASR 1998 Part 91 would look to CASR 91.250 (control locks) rather than CAO 20.2 section 2, but the order may still be referenced in older maintenance approvals.

Finally, CAO 20.2 may be relevant in civil litigation for negligence. While the order does not create a private right of action, a breach of a safety regulation can be used as evidence of breach of duty of care in a tort claim. A plaintiff who alleges that a pilot failed to remove a control lock before take‑off would point to section 2 of CAO 20.2 as the standard of care expected. Compliance with the order would be strong evidence of reasonableness.

The compilation notes disclose two amendments between 2004 and 2006.

The base instrument, Civil Aviation Order 2004 No. R1, was notified in the Gazette on 8 December 2004 and commenced on the same day. This order replaced the prior version of CAO 20.2 in its entirety; the Table of Amendments shows that section 20.2 (the whole order) was “rs.” (repealed and substituted) by that instrument.

The only subsequent amendment shown is Civil Aviation Order 20.2 Amendment Order (No. 1) 2006, which was registered on the Federal Register of Legislative Instruments on 15 May 2006 and commenced the following day, 16 May 2006. The amendment affected subsection 6 (which is actually section 6 in the numbering of the order, covering fuel quantity measurement). The Table of Amendments records it as “am. CAO 20.2 2006 No. 1”. The effect was to insert a new paragraph 5.1A, which created the hot‑refuelling exemption for fuel system water inspections. The amendment also renumbered existing subsections? The text shows paragraph 5.1A was added; the original paragraph numbers were not changed. The note to paragraph 5.1A explicitly says “This does not effect the requirement to do so before the start of each day’s flying.” That suggests the amendment was intended to address industry concern that routine post‑refuelling checks were impractical during rapid turnaround hot‑refuelling operations, while preserving the daily check as a baseline safety net.

No further amendments are recorded in the compilation. The compilation was prepared on 15 May 2006, so it reflects the state of the law as at that date. Since then, CAO 20.2 may have been amended further, but the user’s source does not show any later changes. The order remains in force as at the time of this writing, though it is increasingly superseded by CASR 1998 for operations under that regime.

The amendment history is notable for its brevity - two instruments in less than 18 months, and only one substantive policy change. This suggests the order was not heavily contested or subject to frequent revision. The 2006 amendment was likely driven by a specific industry incident or by CASA’s recognition that the absolute rule against skipping post‑refuelling checks was impractical for hot‑refuel operators.

The source text contains no references to any court or tribunal decisions concerning CAO 20.2. The compilation notes do not list any case annotations, and the order itself does not mention any litigation. This does not prove that no case has ever considered the order; it simply means that no such case is recorded in the source provided.

In practice, CAO 20.2 may have been cited in administrative appeals concerning licence or certificate suspension, particularly where a pilot or operator contested CASA’s enforcement action. For example, a pilot who was found to have failed to test flight controls before taxiing might appeal to the Administrative Appeals Tribunal, arguing that the order was not breached because the test was performed after taxiing but before take‑off. The tribunal would need to interpret “immediately before taxiing for the purpose of taking off” in paragraph 2.5. Such interpretations may have occurred but are not documented in the source.

Similarly, paragraph 2.4 (high‑wind inspection) could have been litigated in the context of an accident where the aircraft had been parked in 35‑knot winds and the pilot did not inspect. If the accident was attributed to control system damage from wind gusting, compliance with paragraph 2.4 would be a central factual issue. But again, the source gives no indicia.

The absence of litigation history suggests that most regulatory action under CAO 20.2 is resolved by consent or by administrative actions that do not reach a public tribunal, or that the order has been sufficiently clear that few defendants have a plausible defence.

From a compliance perspective, the lack of case law means the boundaries of the order are untested. For example, what constitutes a “significant quantity” of water under paragraph 5.2? Is one drop in a sample significant? The order does not say. Without judicial interpretation, operators and pilots must rely on CASA’s guidance or industry standards, which creates uncertainty and potential inconsistency in enforcement.

Several aspects of CAO 20.2 are easy to overlook or misinterpret.

The taxying trigger. Many duties are triggered by “immediately before taxiing for the purpose of taking off”. That language appears in paragraphs 2.5, 3, and implicitly in 2.2 and 2.3A. It means the duties must be performed before the aircraft begins to move toward the runway with the intention to take off. A pilot who performs the flight control test while taxiing out is technically late. If the pilot taxies to the holding point and then performs the test, the test is not “immediately before taxiing”. The note to paragraph 2.5 reminds that paragraph 244(1)(a) of CAR 1988 requires testing “immediately before taking‑off”, so there are two sequential duties: test before taxiing under CAO 20.2, then test again before take‑off under CAR 1988. Many pilots may skip the first test, relying on the second, but that would be a breach.

The high‑wind inspection gap. Paragraph 2.4 applies when winds exceed 35 knots and the controls were not effectively restrained. What is “effectively restrained”? A person in the cockpit may be considered effective, but what about gust locks that are not CASA‑approved? The order says “approved control surface gust locks”. If the operator uses unapproved locks, the pilot must inspect even if winds are only 36 knots. The duty also applies if the aircraft was taxied or towed in such winds - not just parked. A pilot who taxies in a 40‑knot headwind and then parks without using gust locks must inspect before the next flight. Moreover, the inspection is required only if the controls were “not effectively restrained”. If the operator uses unapproved locks, they are arguably not “effective” under the order, so inspection is mandatory. The language invites argument.

The solo‑flight dual‑control removal. Section 4 says “if the second control column is readily detachable, it must be removed.” This applies to any aircraft with dual controls flown solo, not just training aircraft. A pilot ferrying an empty right seat who leaves the detachable control column in place is in breach. The provision is rarely observed in practice, which may create enforcement vulnerability.

The hot refuelling exemption is limited. Paragraph 5.1A exempts only the post‑refuelling inspection. The daily inspection is still required. Furthermore, the exemption applies only if the hot refuelling is conducted “in accordance with section 20.10 or section 20.10.1”. Those orders likely impose specific safety conditions. If the operator cuts corners on the hot refuelling procedure (such as not having a fire extinguisher ready), the exemption evaporates, and every post‑refuelling check must be performed. A pilot who routinely skips post‑refuelling checks because they assume it is hot refuelling may be caught out.

The “significant quantity” of water. Paragraph 5.2 says “if, at any time, a significant quantity of water is found”. The order does not define “significant”. Is 1 ml in a 200‑litre tank significant? What about a visible droplet? CASA could argue that any detectable water is significant because water in fuel is inherently dangerous. The note emphasises that checks must be “positive in nature” and not rely on colour or smell, which implies that even a tiny amount should be detectable. The safest interpretation is that any water found must be removed. The ambiguity gives CASA wide discretion.

The operations manual requirement for larger aircraft. Paragraph 6.1 requires the operator to include “instructions and procedures for the pilot in command ... to verify the quantity of fuel on board the aircraft before flight.” The order does not specify what those procedures must contain. A minimal procedure that says “the pilot shall check the fuel gauges” may satisfy the letter of the order but could be insufficient to prevent fuel mismanagement. The cross‑reference to Airworthiness Bulletin 28‑002 is advisory only, so a court might find a generic procedure insufficient if an accident occurs. Operators should treat the bulletin as de facto mandatory to avoid liability.

The exhibition requirement in paragraph 2.3.2. When a person other than the pilot removes locks, the items must be “exhibited to the pilot in command or co‑pilot from a position which will enable him or her to readily determine that all pins, locks and devices are being displayed.” That means the ground staff must physically show each item, not just call out that they are removed. The pilot must visually confirm that every lock is accounted for. In practice, this can be difficult at night or in poor weather, even though paragraph 2.3.3 requires adequate lighting. A pilot who accepts a verbal confirmation without visual verification risks breaching the duty under paragraph 2.2 to ensure removal.

Commencement of taxiing before co‑pilot confirmation. Paragraph 2.3A prohibits the pilot from starting taxiing unless the co‑pilot has told the pilot that the lock has been removed, either by the co‑pilot or by a third party in accordance with paragraph 2.3. This means the pilot cannot simply see that the lock is gone; the co‑pilot must provide a verbal assertion. If the pilot is flying single‑pilot, there is no co‑pilot, so paragraph 2.3A does not apply; but then paragraph 2.3.2 (exhibition to pilot) applies. The interaction is complex.

The maintenance engineer option for high‑wind inspection. Paragraph 2.4 allows the inspection to be performed by “the pilot in command or an appropriately licensed maintenance engineer”. If the pilot chooses the maintenance engineer, the engineer must be “appropriately licensed”, meaning a licence covering the aircraft type. Using an unlicensed engineer does not satisfy the order. Also, the inspection must be completed before flight. If the ground engineer is not available, the pilot must personally inspect; the order does not allow deferring the inspection.

Compliance with CAO 20.2 requires systematic integration into pre‑flight procedures. The steps below are grounded in the order’s text.

Locking device removal procedure. Before any taxiing for take‑off, confirm that all external control surface locks, undercarriage pins, and other external restricting devices are removed. If the pilot in command or co‑pilot removes them, that satisfies paragraph 2.2. If a ground staff member removes them, establish a written procedure: the pilot must direct the removal; the ground staff must physically hold and display each item to the pilot or co‑pilot, who must visually verify that every lock is present; the pilot or co‑pilot must give an agreed acknowledgement (such as a thumbs‑up or verbal “clear”). For night operations, ensure the parking area is illuminated sufficiently for the pilot to see the items displayed. If the aircraft has been left unattended, consider whether someone else may have fitted a lock without the pilot’s knowledge - the procedure must account for that risk.

Single‑pilot operations with co‑pilot not available. If there is no co‑pilot, the pilot must personally ensure removal. There is no alternative to paragraphs 2.2-2.3; the pilot must either remove the locks or direct and visually verify removal by another person. The confirmation process cannot be delegated verbally without visual display.

High‑wind inspection. After winds exceeding 35 knots, determine whether the aircraft’s controls were effectively restrained. If they were not (including if only unapproved gust locks were used), the pilot or a licensed maintenance engineer must inspect control systems and surface attachments for damage before the next flight. Document the wind observation and the inspection result. Keep a log.

Flight control test. Immediately before taxiing for take‑off, perform a full‑travel test of all flight controls - ailerons, elevator, rudder - and any other necessary tests. Do not rely on the later test before take‑off required by CAR 1988. The test must be conducted from the cockpit, after the locks are removed. If maintenance work on control surfaces has occurred, the test is mandatory regardless of whether locks were present.

Door and hatch security. Before taxiing, physically check all doors, escape hatches, and loading hatches. For cargo aircraft, this includes checking that cargo doors are locked and that the locking mechanism is engaged. Do not rely on a digital indication alone. A physical walk‑around is recommended.

Solo flight in dual‑control aircraft. If the aircraft is fitted with dual controls and will be flown solo, secure the safety harnesses and any loose articles that could foul the controls. If the second control column is readily detachable, remove it and stow it securely. This applies even if the pilot is the only person on board.

Fuel system water inspection. Before the first flight of the day, and after every refuelling (including partial refuelling), drain a small quantity of fuel from each tank into a clear transparent container. Check for water using an approved method: either the visible demarcation method (put a small quantity of fuel in the container first, then sample; water will appear as a separate layer), chemical water‑detecting paper or paste, or, for turbine fuel, inspection for persistent cloudiness. If the aircraft has an approved manufacturer’s data for water checks that specifies a different frequency or method, follow that data. However, note that the data must be approved under regulation 42M of CAR 1988 as part of the aircraft’s system of maintenance - not merely as a manufacturer’s recommendation.

If the aircraft type is specified by CASA (currently, most high‑performance turbine aircraft), extend the inspection to fuel system filters and collector boxes. Even if not specified, CASA recommends doing so at frequent intervals.

Hot refuelling exception. If the aircraft is to be hot‑refuelled, confirm that the refuelling is conducted in accordance with CAO 20.10 or 20.10.1. If it is, the post‑refuelling water check may be omitted. However, the pre‑flight daily check must still be performed. Keep a record of the hot refuelling procedure to prove compliance with the relevant CAO.

Water removal. If any water is found, remove all traces from the entire fuel system, including filters, before further flight. Consider that water may be trapped in low points or in lines that are not immediately accessible. After removal, repeat the inspection to confirm elimination. Document the finding and the remedial action.

Fuel vent inspection. Before the first flight of the day, visually inspect all external fuel tank vents for blockages - such as insect nests, ice, or debris. This should be part of the daily walk‑around.

Fuel quantity verification (aircraft over 5,700 kg commercial). The operator must ensure the operations manual contains specific instructions and procedures for the pilot to verify fuel quantity before flight. The pilot must follow those procedures. The procedures might include cross‑checking fuel gauges, dipsticks, fuel slips, and flow calculations. The operator should incorporate the guidance from Airworthiness Bulletin 28‑002 to build robust procedures. The pilot should not skip the verification even if the fuel gauges appear consistent.

Documentation and training. Operators should document all these procedures in an exposé to the operations manual or training syllabus. Pilots should be trained on the precise timing of the duties, especially the “immediately before taxiing” trigger. Regular audits of pre‑flight practices can detect deviations before they become breaches.

Record‑keeping. Maintain records of daily fuel inspections, water removal actions, high‑wind inspections, and maintenance engineer inspections. These records are essential to demonstrate compliance in the event of an incident or CASA audit. The order itself does not mandate record‑keeping, but it would be prudent given the gravity of potential consequences.

By integrating these steps into standard operating procedures, an operator and pilot can systematically comply with CAO 20.2 while also reducing the risk of an accident attributable to the hazards the order addresses.