Aviation Marking of Chimneys and Masts: Regulations and Painting Methods

A chimney has been standing for a long time, operating without failure and causing no problems. Then it turns out that an airport has been built nearby, the local spatial development plan has changed, or someone from an authority has simply sent a letter asking whether the structure has the required obstacle marking. If you do not have such documentation or do not know what the regulations require, you are in a situation where you need to act quickly and precisely. Lack of marking on a structure that requires it is a violation of aviation regulations, with consequences for the owner of the structure.

This article explains which regulations govern the marking of aviation obstacles in Poland, when a chimney or mast is subject to marking requirements, how obstacle stripe painting is carried out using rope access, and what documentation is required by the Civil Aviation Authority.

Legal Regulations Governing Aviation Marking

The legal basis for marking aviation obstacles in Poland is the Aviation Law Act and regulations issued by the Minister of Infrastructure and the Minister of Transport. The key documents include:

The Act of 3 July 2002 — Aviation Law: this establishes the general rules for protecting airspace and imposes the obligation to mark structures that constitute aviation obstacles.

The Regulation of the Minister of Infrastructure on technical and operational requirements for public-use airports: this defines the parameters of visual obstacle marking.

The Regulation of the Minister of Transport, Construction and Maritime Economy on the method of reporting buildings and natural objects to the register of aviation obstacles: this regulates the procedure for reporting structures to the Civil Aviation Authority.

ICAO Annex 14, Aerodromes: this is the international standard referenced by Polish regulations. It defines detailed requirements for visual and lighting markings of aviation obstacles.

The marking obligation applies to the owner or manager of the structure. This is not a matter that an authority resolves for you. It is your formal and practical responsibility. An unmarked structure that should be marked exposes the owner to administrative liability and, in the event of an aviation accident, also to civil and criminal liability.

When a Chimney Requires Aviation Marking

Not every chimney and not every mast is subject to mandatory marking. Regulations and ICAO standards define several criteria that determine whether a structure is an aviation obstacle requiring marking.

Height criterion: structures higher than 100 metres above ground level generally require obstacle marking. Lower structures may also require marking if they meet other criteria.

Distance from an airport criterion: structures located within designated airport surrounding zones are subject to special requirements, which may lower the height threshold requiring marking. This zone is defined by the President of the Civil Aviation Authority in agreement with the airport operator and covers an area with a radius depending on the airport class.

Airport obstacle limitation surfaces criterion: if a structure penetrates the approach, take-off, or transitional surface designated for a given airport, regardless of its absolute height, it is subject to notification and may require marking or a Civil Aviation Authority decision on the admissibility of the obstacle’s existence.

Flight route criterion: structures located near published arrival routes, instrument approaches, or in TMA areas, meaning terminal manoeuvring areas, may be subject to an individual marking requirement based on a decision of the Civil Aviation Authority.

If you are not sure whether your structure meets these criteria, it is worth checking both the regulations and the Civil Aviation Authority’s aviation obstacle register. A structure may be entered in the register with a historical marking decision that the current owner is unaware of.

Methods of Painting Obstacle Stripes Using Rope Access

Visual marking of aviation obstacles by painting consists of applying alternating stripes in orange, aviation orange, and white or red. The stripe parameters, including their number, width, and arrangement, are specified in ICAO Annex 14 and must be precisely maintained.

Painting obstacle stripes using rope access proceeds as follows.

Measuring and setting out the stripes: based on the total height of the structure and standard requirements, the number and width of stripes are determined. The stripes are measured from the top of the structure downward. Each stripe is marked around the circumference of the chimney using a guide line or tape, which provides a reference point for the painters.

Surface preparation: before marking paint is applied, the condition of the coating is assessed and, if necessary, the substrate is prepared in a manner similar to standard anti-corrosion painting. Markings are not applied over old, weak coatings. The stripes must remain durable for many seasons without edge flaking.

Paint application: specialist paints for obstacle marking are used. They must be UV-resistant, weather-resistant, and provide the required visibility characteristics. The stripes are painted by brush, roller, or spray application, with masking at colour transitions to achieve a sharp line.

Reflectivity and night visibility: painting alone does not replace requirements for obstacle lights. ICAO standards require the use of obstacle lights at night and in poor visibility. Painted stripes are a daytime requirement. For many structures, both requirements must be met at the same time.

Post-Work Documentation Required by the Civil Aviation Authority

After aviation marking has been completed, the owner or manager of the structure should have documentation confirming that the marking was carried out in accordance with the requirements. This documentation may be required during an inspection, when changes are made in the aviation obstacle register, or during administrative proceedings concerning the structure.

Complete post-work documentation should include:

•a work completion protocol, including the scope of work, completion date, stripe parameters, such as number, width, and colours, and the painting materials used together with technical data sheets;

•photographic documentation, with photos showing the marking from different sides and levels, preferably with scale and distance identifiable;

•technical data sheets and approvals for the paints used, confirming resistance to UV radiation and weather conditions;

•a statement by the works manager confirming that the work was carried out in accordance with ICAO Annex 14 and Polish aviation regulations;

•registration data of the structure, if the structure is or should be entered in the Civil Aviation Authority’s aviation obstacle register, including its location, coordinates, height above sea level, and height above ground level.

The lack of post-work documentation does not invalidate the marking itself, but it makes it difficult to demonstrate compliance before supervisory authorities. When ownership of the structure changes, when the marking is renovated, or during a Civil Aviation Authority inspection, documentation from previous work is the first document an inspector will ask for.

Does Your Structure Require Marking?

If you have a chimney, mast, or another tall structure and you are not sure whether it is subject to obstacle marking requirements, this is worth checking before you receive a letter from an authority. Verification involves checking the parameters of the structure against height and airport distance criteria and, in case of doubt, sending an enquiry to the Civil Aviation Authority or consulting a specialist experienced in carrying out obstacle marking projects.

If you know that your structure requires marking to be refreshed or completed, ask about implementation. We can discuss the scope of work, the parameters required for your structure, and a completion date compliant with the regulations.