Margin for 50 hourly/oil & filter change

[PlankBlender]

Quick question for the LAME's and insurance experts out there:

I have just over eight hours left until the MR for my Archer stipulates an oil/filter change, and I'm planning a trip that could get me very close or if I need to divert majorly, maybe over that figure.

My MR says 'Oil cx + filter insp IAW Lyc SB 480E' at '7339 (or F/SW 1889) or each 4 mths'.

How much leeway do I have insurance-wise and re. upsetting CASA with this, i.e. can I go over a couple of hours F/SW and if I have an engine failure and subsequent damage will the insurance company turn around and refuse to cover it (and CASA may fine me), or is it generally accepted that you can't hit the 50 hours spot on and can do it when it suits, assuming of course you don't stretch it too unreasonably (like 5-10 hours over)?

Same with the four month time limit, is it going to be a problem if I fly a couple of times after the four month period before I get the oil change done, or could that get me in trouble?

Cheers! :ok:

[gas-chamber]

With aircraft under a maintenance control system eg RPT and charter it is not unusual to get CASA approval to over run some checks by a few hours. In commercial operations I have certainly seen extensions approved up to 10%. I don't know the legal answer to your situation as a private operator but would strongly advise that you get some sort of approval in writing to cover yourself in case of an incident. In practical terms, if the engine has had regular use then running it 5 hours over the oil/filter interval is highly unlikely to cause it any harm. Maintenance intervals for aircraft are usually conservative.

[flog]

As they would say say in IFR training: +0, -50.

[pcx]

Interesting question.

The Lycoming service bulletin is headed "Mandatory". However the S/B detail commences with "Lycoming recommends".

S/B can be found here http://www.lycoming.textron.com/support/publications/service-bulletins/pdfs/SB480E.pdf

I believe that the S/B is not mandatory so you are not breaking any rules if you fly beyond the 50 hours or 4 months.

It might also come down to how the entry is worded in your maintenance release ie. Oil change and filter required at xxxx as distinct from IAW Lycoming S/B Oil change and filter required at xxxx. Just my opinion.

I am keen to see what the engineers think about this.

[djpil]

Have a read of AD/ENG/4 (http://www.casa.gov.au/wcmswr/_assets/main/airworth/airwd/ADfiles/enggen/eng/ENG-004.pdf)Requirement A3(a) - At intervals as published by the engine manufacturer with a planning tolerance
of plus or minus 10%.

[Atlas Shrugged]

I'm not sure (and no doubt someone will point it out if I'm wrong!!) but there is/used to be provision somewhere in the regs for a flight "to maintenance" or something along those lines, so if you go 50 or slightly over and you are away from base, you still can "legally" fly the aircraft to the maintenance organisation, but the flight must only be for the purposes of repositioning the aircraft for maintenance.

[QNH1013.2]

I would have thought that your LAME could allow this to occur if you asked them.

I have the same problem, I'm 10 hours from my 600 hourly and if I go on my proposed trip over easter I'll go over. It's a pain in the butt. Luckily I can just write myself a new maintenance release. :D

I remember talking with some guys who flew from Perth to Melbourne and planned to go back again. They didn't allow for such a headwind and needed to go over the MR in hours, so they rang home and got it approved by the LAME so I just always assumed that it could be done.

[blackhand]

QNH says:
I have the same problem, I'm 10 hours from my 600 hourly and if I go on my proposed trip over easter I'll go over. It's a pain in the butt. Luckily I can just write myself a new maintenance release.

Or how about this, don't do any maintenance and fly it until it falls out of the sky.
Will save you lots of messing around.



Aviation has a perfect record - we've never left one up there

[blackhand]

Hi Planky
To answer your question the 50 hour oil change is recommended for the longevity of the engine, is not really a safety issue.

If you are the aircraft owner you will want to keep the costs of your engine overhauls down, the oil change interval helps with this.

Just plan to be at an airport were you can carry it out, for private operations oil change is listed as pilot maintenance.

Don't be like one of my customers with a Bell 473B1, landed 30 minutes short of his destination in a paddock because his oil and filter change was due. Ended up with a screwdriver stuck through the filter and no way out.

Duty of care as a LAME prevents me from recommending anything other than the OEM continuing airworthiness data, but commonsense should prevail.

[Mr_Pilot]

I am of the practical belief that 10% is a good margin to allow.

I do follow the directions as laid out on the MR, and as this is a legal document I suggest you should to. No doubt some ambulance chaser somewhere would try and stick you for the replacement cost if anything was to go wrong.

I have been taught this rule by many experienced pilots and LAME's alike, but there is no reasoning for it - as per documents. I have only ever changed the oil and filter after a flight, as left to drain cold it takes for ever, and after runnning it in, the engine engine will not have scavenged the oil yet, and thus allowing a greater amount to be changed for clean - I think :uhoh:

As pr the insurnance company. Ask for thier reccomendation and make sure you get it in writing if you are becoming a little sceptical. Most insurers are happy to work with you, and usually have some very knowledgeble and experienced staff on their books.

But I still agree with 5 hrs or as it is in most cases (10%). :ok:

[Socket]

AD/ENG/4 Amd11 does not recommend oil changes, it requires them to be done. It has given a standard + or - 10% tolerance. Previous amendments allowed the tolerance only if the manufacturer gave one ( continental yes, lycoming mostly no). It also now requires a filter change, previous amendments allowed for long filters on continentals to go for 100 hours.

So in short, yes you have a tolerance of 10%, and you DO have to do one. I am sure amendment 12 will move the goal posts again.

[blackhand]

Hey Socket
Thanks for that update.
Been working out of country for a while.
That means it is mandatory - no way around it.

And Mr_Pilot - there is a very good reason for changing oil when it is at operating temperature, other than to annoy the LAME!! Think sludge, condensation etc.

Blackhand

[bentleg]

I may be conservative but IMHO if the MR says OC by certain hours, in my opinion that's it - the flight that makes it go over that number is the last one without an OC. A phone call to the LAME may get you home, but I would prefer not to get into that situation. In the situation being discussed I would have the OC done before I go (or get the the LAME to extend the time requirement on the MR before leaving).

If the LAME has endorsed a + or - margin on the MR then no worries extending to that limit (but not beyond it).

[Torres]

Some years ago our approved Maintenance System Manual permitted an existing flight to continue if a manitenance inspection became due. However a flight from a maintenance base could not be planned and undertaken if the planned flight hours exceeded the available MR hours to next inspection.

[mudpig]

Be very careful with this one. Agreed with contacting insurer and getting it in writing. Reason for this is your MR states 50hrs or 4 months. If the engineer didn't put +/-5hrs adjacent to the 50hrs I would stick to the 50hrs, especially if no letter comes from the insurer. Unlikely an engine failure will occur due to stretching the change of oil and filter an extra 5 hrs. But, murphy reckons it'll happen. Highly likely then the insurer is gonna 'say sorry pal you didn't stick to your MR requirement .... I don't care what AD/ENG/4 says, cos your MR says 50hrs'.
You could just save yourself the trouble and get the oil and filter changed before you go. It shouldn't take any longer than an hour or two and you'll have nothing to worry about.:ok:

[Clearedtoreenter]

Oil and filter is allowed pilot maintenance and not too difficult. Chuck a filter a few quarts of oil in the back and DIY when due.. Don't forget to sign it off on the MR. As for the +/-10%, I think it has to be written somewhere (MR, logbook?) for it to be valid.

[YoungAggy]

Why not replace oil & filter before you go -save all the hassle & worry.Nothing in the regs to say it cant be changed early.Unless The a/c is used frequently it may not do another 50 hrs before the annual is due anyway - hence no real extra cost etc.:ok:

[Jabawocky]

I reaise bigger more complex machines require a bit more thought, but we are talking a Piper Single here.

Its about $80 for oil and bugger all for a filter so do it early! :ok:

Fresh oil and a happy engine!:)

[that chinese fella]

Plank, the first and only place you should look first to answer your question is your aircraft's logbook statement (LBS) Part 1.

This will indicate under what maintenance schedules the aircraft is bound by. The LBS should ideally be signed by the registered owner/operator as saying 'yep, I accept that'.

Further the AD/ENG/4 may not be applicable at all as it states that only if you are maintaining it IAW CASA schedules. Again, check the LBS first.

pcx has a good point, it also depends on how the 50 hrly is written up. Technically the Lyc SB mandates the filter to be opened up and inspected, which IS NOT covered under Schedule 8 - Pilot Maintenance - a small but important issue.

Do/get it done early and save the hassle! :ok:

[PlankBlender]

Great advice as usual here, thanks heaps! :ok:

My MR stipulates 'CASA maintenance sch 5 + PA18-181 mm', so I guess ENG4 applies and with that the 10% tolerance.

Oil and filter change are getting done today, the question was primarily one of liability and practice. In this country what the regs state and what is applicable practice often vary considerably. I'll still double check with the insurer for good measure, though, you never know, they will take any opportunity to wriggle themselves out of coughing up :rolleyes:

ENG4 also states that filter inspection is not needed when the pilot does it, so I suppose that overrules the Lycoming SB (I wish there was some no-nonsense advice by CASA on this, both of their maintenance guides for owners and operators don't even mention owner oil changes:ugh:):

A3(b) Engine oil filter, oil pressure screen and suction screen inspection
All engine oil and engine oil filter replacements, including those carried out in the period between the aircraft periodic inspections, unless carried out by a pilot, shall include inspecting the engine oil pressure filter, oil pressure screen and, if applicable, the oil suction screen, for evidence of metallic particles, shavings or flakes. Take corrective action, where necessary

Follow-up question here: Where does one do a pilot oil and filter change these days? I'd be more than happy to do it myself rather than pay someone a couple of hundred bucks for the privilege, but I'm not sure it'll be looked at kindly if I put a can under my plane on the grass at Archerfield.. and I'd then just drive the old oil to the nearest depot or what? :confused:

[bluesky300]

Slightly off topic, I once saw a RCA from CASA that turned into a show cause. An eroplane had flown in excess of a 100 hrly inspection. The operator replied that the over-run was inconsequential and due to operational requirements of the flight in question.

It was then hit with a further RCA and show cause based on its failure to comprehend its obligations to safety and maintenance.

How far over 100 hrs had the aeroplane gone you may ask?

.02 of one hour. 1.2 minutes.

[blackhand]

Plankbender
Contact Murray Bolton at Helico at Archerfield.

He will help out

Blackhand

[PlankBlender]

Cheers, blackhand, will contact him next time!

Here's the statement from my insurer:

i confirm that compliance with AD Eng 4 rather than the manufacturers requirements will not void the insurance cover.

This means there is no need for a filter inspection in an owner executed oil and filter change, and they cannot refuse liability if you have an engine failure after such maintenance.

[blackhand]

This means there is no need for a filter inspection in an owner executed oil and filter change, and they cannot refuse liability if you have an engine failure after such maintenance.

That's a valid viewpoint, but another view point is that this would be the least of your worries at 5000 Hp when the "fan, pilot cooling" stops.

Have a look in the filter, any "shiny" bits you see may indicate an impending failure.

[PlankBlender]

blackhand, I'm not saying I wouldn't, but I can't certify a filter inspection on the MR and as such it's useless for liability purposes, hence my question to the insurer.

[PercyWhino]

Remember to also Lockwire the filter again when you do him up. Sorry for stating the obvious but make sure you lockwire it so that the wire is "doing it up" if you will.

Another question.

If you have been shown by a LAME and "signed off" on sched 8 can you sign off the MR for that item. I.e. Can PlankBlender sign off the MR as 50hrly oil change completed?

[Socket]

If you have been shown by a LAME and "signed off" on sched 8 can you sign off the MR for that item. I.e. Can PlankBlender sign off the MR as 50hrly oil change completed?


Not only can he sign for it, but he MUST sign for it.

It is a legal requirement and nothing is surer to upset a LAME than to find out a pilot/owner has been carrying out maintenance on an aircraft with the LAME's signature on the MR and the pilot/owner made no entries or certifications for that maintenance.

If the oil filter or wheel or whatever falls off or fails and the last signature is the LAME's he is going to cop the fallout from CASA. I have refused to maintain certain owners aircraft because they insist on doing their own oil changes, tyre changes etc.... but do not enter it on the MR. Might cost me some business in the short term but protects my earning capacity in the long term.


Further the AD/ENG/4 may not be applicable at all as it states that only if you are maintaining it IAW CASA schedules. Again, check the LBS first.



That chinese fella,

AD/ENG/4 is ALWAYS applicable no mattar what system of maintenance you are on. AD's are always mandatory over and above sched 5 or the manufacturers system or your own CASA approved system. So it (ENG/4) is the minimum you have to do.

[Sunfish]

Plankbender, why not drain the oil filter, bag it and give it to your LAME to check later.

[bellsux]

Socket.

I think you are wrong as the first line in the AD clearly states that the AD is applicable to aircraft maintained under CAR 42B which is the CASA maintenance schedule. So as That Chinese Fella said it all comes back to the Log Book Statement and what system is applicable to that particular aircraft.

So if Plankbenders log book statement does not have IAW CAR42B he could possibly be in for a rude shock from CASA or his insurance company even though he does have that nice letter because not 'in compliance with AD/ENG/4' and if an adjuster or CASA picks this out it could be expensive.

So if you then want to change over to the CAR42B system all the other requirements must be carried out as listed in the AD. So I would think that having Manufactures or Lycoming in the LBS is the same as having IAW CAR42A in the statement not making AD/ENG/4 applicable.

[bellsux]

also.. if a LAME has endorsed the maintenance release with 'Oil cx + filter insp IAW Lyc SB 480E' at '7339 (or F/SW 1889) or each 4 mths'. it will have to be carried out regardless of AD/ENG/4 and as that SB does include filter screen inspection and filter disassembly / inspection which a pilot cannot carry out under Schedule 8. For example if the engine had made metal previously or any other maintenance concern this could be added as an extra requirement to the AD.

Discussing this with the maintenance organisation and the LAME that issued the MR is the best advice.

[tnuc]

I think you are wrong as the first line in the AD clearly states that the AD is applicable to aircraft maintained under CAR 42B which is the CASA maintenance schedule. So as That Chinese Fella said it all comes back to the Log Book Statement and what system is applicable to that particular aircraft.



If you are not maintaining to the CASA Maintenance schedule then you will most likley be maintaining your aircraft manufactures schedule, most manufacturers require oil/filter to be serviced as per the engine manufactures requirements so you are back to say 50Hr/4Mth for example

You could be on your own system of maintenace approved by CASA however they are nearly always going to use either the CASA schedule or Mfr's schedule as a Minimmum when approving your system.

End of the day, the cheapest parts you can put on/in your engine is OIL FILTER and the FUEL

[blackhand]

I have to smile, as an old hand said to me once: Get 4 LAMEs in a room and you will get at least 5 answers to the problem.

Change the oil. check your filter and sign it off.
We are not talking about a 747 here.

Blackhand

[bellsux]

Yeah good idea blackhand, those CARs, ADs and all those other rubbish rules are too difficult to read and understand so lets all just do as we please to make it easier on everyone.

[blackhand]

BELLSUX - and by the way no they don't!!!

The reality is that a simple issue has been turned into this long winded discussion - as I said before get 4 LAMEs together and you will get atleast 5 answers.
And BTW I have been a licenced mechanic for nearly 30 years.

[bellsux]

Plankbender, this thread has bent out a bit from your original question and the answer lies in CAR41 (1)

The holder of the certificate of registration for a class B aircraft must
ensure that all maintenance required to be carried out on the aircraft
(including any aircraft components from time to time included in or
fitted to the aircraft) by the aircraft’s maintenance schedule is carried
out when required by that schedule.

Also read CAR 42 A, B, C and D along with Log Book Statement to find out which system you are using for maintenance and if it is CASA Schedule 5 note that it includes all categories airframe, engine, electrical, instrument and radio. Your MR stated in an earlier thread that it was marked on the Part 1 , CASA and Piper schedules, if so it would mean that you most likely have a CASA approved system under CAR42C as CAR 42D talks about, in which case AD-ENG-4 does NOT apply as it states clearly in applicability that it only covers 42B.

If want your LAME to swap the system under 42B and AD-ENG-4 giving you the freedom to carry out 50 hour oil and filter changes all the other prerequisites detailed in the AD will have to be complied with.

Finaly I really dont want to continue this topic as there is only one set of rules that apply to this thread and its digressions, it is only a few pages long, simple to understand and it is the LAW (note CAR41 (3) An offence against subregulation (1) or (2) is an offence of strict liability. Note For strict liability, see section 6.1 of the Criminal Code. You dont need four LAMEs or a forum to interpret their undersandings of it as there is only one set of simple answers under Part 4 Maintenance and if you have any difficulties you should approach your nearest CASA office to clarify it.

[tnuc]

Herein lies the next problem ..


if you have any difficulties you should approach your nearest CASA office to clarify it.


Ask 4 CASA offices the same question and you will get 5 different answers !

[Clearedtoreenter]

Ask 4 CASA offices the same question and you will get 5 different answers !

So if you don't get the answer you want, just try another one somewhere else, possibly in a different state..... As one said to me when I was trying to reconcile two different views on the same maintenance issue, 'its all a matter of interpretation'. So the only place to really work it out is in court!

[bellsux]

Considering that there are only three options available, 42A 42B or 42C there are no allowances for interpretations, both LAMEs and Certifiate of Registration holders must know them and the implications if they are in breach of them. Some people still obviously have trouble understanding those options as the last two pages show but if it came to insurers not wanting to cough up the cash in a claim or CASA pinging someone the lawyers will spell it out easily enough.

[PlankBlender]

Wow, I'm not easily confused normally when it comes to the law, but you guys did it :}:ok::D

This being my first aircraft, I hadn't really considered pilot maintenance or indeed the intricacies of the maintenance system. I usually just had the LAME deal with it. The oil change issue got me thinking, and again thanks to everyone for contributing, it has opened my eyes for the complexity of the situation.

Here's the verbatim from my aircraft log book:

This aircraft is to be maintained in accordance with the following:
[x] maintenance schedules
[ ] system of maintenance

This aircraft is to be maintained in accordance with the following:

(a) The CAA maintenance Schedule
(b) All specific inspections and lifed component changes which are listed in:
i) a schedule of Airworthiness Limitations contained in the Maintenance Manual applicable to this aircraft;
ii) approved data relating to modifications incorporated in this aircraft; and
iii) approved data relating to modifications incorporated in components installed in this aircraft;
must be complied with.
(c) All Airworthiness Directives applicable to this aircraft must be complied with.
(d) Airworthiness Directives required to be carried out at the Major Inspection must be complied with at intervals not greater than three years.

(Note: (1) This aircraft is exempt from the requirement of a major inspection as specified in CAO 100.5.1. Section 3.3.

As a reminder, my MR says this:

My MR says 'Oil cx + filter insp IAW Lyc SB 480E' at '7339 (or F/SW 1889) or each 4 mths'.

My MR stipulates 'CASA maintenance sch 5 + PA18-181 mm'

CAR42B stipulates that

if..the holder of the certificate of registration..has elected to use the CASA maintenance schedule..the aircraft's maintenance schedule is the CASA maintenance schedule.

So assuming Piper refers to Lycoming for maintenance of the engine (and therefore the Lycoming SB being part of the Piper maintenance manual which is then part of the maintenance schedule), I still have the difference between the Lycoming SB stipulating filter inspection, and ENG4 not requiring it when the pilot executes the oil change.

My insurer's statement lets me to believe I can choose whether to do it myself (i.e. without filter inspection as per ENG4) or have my LAME do it (with inspection according to the SB), and it will have no effect on liability or indeed compliance with the law. Anyone beg to differ?

Could I execute that choice every time an oil change comes up? :confused:

[blackhand]

Wow, I'm not easily confused normally when it comes to the law, but you guys did it

BELLSUX
Considering that there are only three options available, 42A 42B or 42C there are no allowances for interpretations

Finaly I really dont want to continue this topic as there is only one set of rules that apply to this thread and its digressions, it is only a few pages long, simple to understand and it is the LAW

Tnuc
You could be on your own system of maintenace approved by CASA however they are nearly always going to use either the CASA schedule or Mfr's schedule as a Minimmum when approving your system.

Socket
It is a legal requirement and nothing is surer to upset a LAME than to find out a pilot/owner has been carrying out maintenance on an aircraft with the LAME's signature on the MR and the pilot/owner made no entries or certifications for that maintenance.

No wonder you are confused Plankbender.
And can probably explain why it takes so long to get a simple oil change carried out by some of the mechanics posting here. LOL

I spoke with Airworthiness (Eastern) about this issue and they would have no problems with the owner/pilot carrying out this simple task on his own aircraft.

Look after your aircraft and it will look after you.

Blackhand

[Joker 10]

Try a read of CAAP 8 pilot maintenance, illuminating and enabling document.

[blackhand]

Good one joker, a smart card in the pack. LOL

[bellsux]

Try a read of CAAP 8 pilot maintenance, illuminating and enabling document.

:ugh:

Seeing as such a document does not exist it would be quite easy too read and understand.. or maybe try CAAP 42C-1(0) Approved Pilot Maintenance for Class B Aircraft (1992) or CAR Schedule 8 (August 2003) and if you have passed AA, Admininstation CPL or ATPL you would know the differences between the two documents.

[Socket]

Blackhand,

I really couldnt care less if a pilot chooses to do his own maintenance as far as sched 8 allows. AS LONG AS HE SIGNS FOR IT. Pulling out quotes without reading them in context is the sure sign of a Jerk.

You say you have been a licenced mechanic for decades, big deal,a car mechanic without a drivers licence is fairly useless.

I have been a licenced aircraft maintenance engineer for decades.

[blackhand]

Socket
You and I are in agreement about pilot maintenance and the requirement to sign for the same on the maintenance release.

On the subject of "mechanic" and "engineer" I was a mechanic on complex ground equipment prior to changing over to aircraft maintenance and still consider myself a mechanic first. The new breed of "engineers" are fully qualified, can quote aircraft theory and CASA regulations at one verbatim, but couldn't trouble shoot their way out of a wet paper bag with a two handed axe.

in context is the sure sign of a Jerk.

Do you think that is called for? The quotes were to highlight the diversity of opinion amongst "engineers" on this simple topic. Be at peace with the world on this holiest of sundays.:ok:

[bellsux]

Well that explains a lot, so if you don't know the regs why comment? Wouldn't that be misleading and dangerous? Regardless of how brilliant a mechanic you say you are, you have a responsibility if you hold an engineering licence to know and follow them, that is what a major part of what an AME licence is for, not some paper to show how skilled you are at fault finding. I have all along backed up my comments with references and facts not generalisation, returning to the original question. If you sit down, read and try to understand AD/ENG/4, Part 4 and Schedule 8 of the CARs and rather posting irrelevant comments on the net perhaps in future you wont have to call CASA and get them to explain it to you.

[blackhand]

Mmmmm
Just hanging around for the blue are we, sorry its Easter Sunday and against my religion.

I take it from your answer that you are the local crew room lawyer that every one so loves.

And your ESP needs retuning if you want to mind read me.

Seems like the aside about incompetent mechanics hit close to home - wooops.
And maybe your personalty is what is keepng the clients away.:rolleyes: