Ladies and gents, Related a little to powerlimited's post elsewhere: I'm not after the Part M Appendix VII definition of a complex task which largely relates to those tasks a Part 66 LAE cannot do unless operating under the auspices of a Part M Subpart F AMO.
I'd like a breakdown of the definition of complex in the context of Part 145.A.45 (Maintenance Data) (paraphrased): "...complex tasks shall be broken down etc... to allow task recording..." Reason? We're trying with little success to get our certifying staff to do it and one - who rightly argues for the definition of a complex task - asked me to define it. He brought up the M Appendix VII definition above but I think this is literally out of context. I did argue for the application of a little common sense...
Beeline, I assure you that you are pushing at a wide-open door here; I've never been at a place where it has been so difficult to convince the AMO staff to do what the procedure says rather than what they want to do. We've brainstormed, discussed and agreed then many go ahead and disregard. We publish procedures, we have informal talks. We have a system where they can suggest changes, come up with better ideas. Unfortunately, change of this type seems to affect what is fundamental to a commercial business: the bottom line, billable time etc.
I believe this requirement was introduced into 145.A.45 following the serious incident that occurred to an Excalibur A320 during in a line maintenance non scheduled flap change. The AAIB report published in 1994 is comprehensive and provides a great deal of background information that 145 AMOs could refer to when preparing their own procedures. It is well worth a read to be reminded of the traps and pitfalls that await the unwary or unprepared. http://www.aaib.gov.uk/cms_resources...5%20G-KMAM.pdf
Perhaps you could use this report for continuation training and if the AMO staff are not convinced and prepared to play ball in accordance with your procedures then perhaps they should be looking for a new job.
In addition the CAA published an Airworthiness Notice on the subject which is now included as appendix 5-2 in CAAIPs.
An engine change cannot be 'replaced iaw xx-xx-xx/401 function satis' somewhere there must be staged breakdown of each task.
Sure it can, normally there is a maintenance manual that describes the procedure and provides the necessary ops checks. Sorry I sort have overshot the 145 part, this would be in your manufacturer supplied heavy maintenance package, for instance boeing would supply a engine R&R job task card starting with pulling and tagging breakers and finishing with an engine run, it would mimic the AMM but allow for tasks to be accounted for in order .
Thanks to all for the above. Believe me, I've been in aviation since 77 and have acted as QA auditor, manager, Part M CAM, Subpart G QM, LAE, trainer - loads of stuff; I've run training in HF, Parts 145, M, FTS etc, etc. I've never experienced the reluctance I relate to you in the past.
What we were/are trying to achieve where I am now is no more onerous than I've seen elsewhere. Finally, I stood in front of a team of guys this morning and went through exactly what is required (after all that I'd described earlier) and I think we may have made some progress; audit will tell
Let's face it the whole lot is daft.... I still think it is odd I can change an engine, refit a wing or complete tail assy and though there is dupes for any disturbed controls, there are none to check the wing or engine are correctly bolted on, I get someone to look over them for me as an extra check when they do the dupes, but there is no requirement for it.
A LAE has the privilege of raising additional worksheet(s) to supplement task card which he deems inadequate. Any grey area can be brought up directly to QA/chief insp. etc to re-issue updated job task.
All AWS raised would be accounted for at the end of a check before final CRS.
What Bus's concern is the accountability of complex job done of UAE engineer (still under JAR system) who would just signed off (e.g. engine c/x) IAW AMM xx.xx.xx. END.
The engine is normally bolted on 2/3 attachment mounts and staged breakdown incl. dup.where required.
The Boeing wing is bolted by 2 bottle pins with bushes and staged breakdown incl. dup. where required.
Cessna???? I have forgotten!!
EASA requires detailed staged breakdown for individual accountability.
LAE is considered a professional engineer who is capable to signing off his own task without supervision and is under the jurisdiction of UK ANO (UK LAE) closely monitored by UK CAA.
Major task like wing removal requires flight test before issing C of A.
I'm sure my organisation isn't the only one that has many in-house engineering forms which are based on the AMM and detail all relavent steps to be taken with mech and LAE sign-off boxes for each task.
Engine change APU change FFG/MEC change
They work well and apart for allowing for correctly staged certification, also ensure that tasks are carried out in the correct order (rather than from memory etc)
Bear in mind you cant rely on AMM for dupes. EASA and FAA run slightly different schemes for this then outside these individual authorities have different systems. So unless you paid Boeing/Airbus etc for a customised AMM for each authority.......
EASA: Any update of a task card e.g PDI, Transit, Daily check or engine change etc would be reflected on the new issue no. and new date. Subsequently, a LAE should annotate that clearly in a T/L entry.
QA and Tech Record duties are to enforce updated copies are distributed to all concerned and old copies destroyed.