Has anyone done SDMP yet?
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Has anyone done SDMP yet?
So LAMP for ELA1 aircraft no longer exists and we need to create our Self Declared Maintenance Program using (probably) the Minimum Inspection Program, but has anyone actually done this yet? And would they be willing to show an example? If it happened to be for a simple aircraft such as a 172, that would be very interesting☺.
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If I was writing one of these I would look at the manufacturers maintenance program and what you have had to do when using LAMP based on the way you use your aircraft. This way you should get the most appropriate maintenance for your aircraft.
One of the places I will be going with the SDMP on my Robin DR400 will be to triple the time between NDT inspections on the landing gear legs, from my observation of DR400 aircraft the inspections called for by the manufacturer are based on aircraft used as glider tugs, discussion with those in the gliding world puts the tug landing rate at about seven per flying hour mostly from grass airfields. Being as I use my DR400 for touring with an average of 0.75 landings per hour I see this as a sensible move.
One of the places I will be going with the SDMP on my Robin DR400 will be to triple the time between NDT inspections on the landing gear legs, from my observation of DR400 aircraft the inspections called for by the manufacturer are based on aircraft used as glider tugs, discussion with those in the gliding world puts the tug landing rate at about seven per flying hour mostly from grass airfields. Being as I use my DR400 for touring with an average of 0.75 landings per hour I see this as a sensible move.
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A friend did in Autumn and said it was PITA. His statement was: in the end you have to comply with the same regulations in the same way, but with SDMP you have nobody to blame and earn all the bad yourself. But, he is a lawyer and a risk averse ...
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Thanks A & C. That's exactly the sort of thing I will be looking at, but because the 172 is so simple there don't seem to be many economies to be made. I am up to speed on all the ADs that affect it (and there's an SB from Lycoming), but there are probably some component parts that I need to understand requirements for.........
Example - hoses need pressure testing every 36 months "until ultimate service life, if stated, is achieved". How do I check if "ultimate service life" exists? (Existing hoses were supplied with factory-new O-360A4M direct from Lycoming but can't find any limit in their overhaul manual)....
Example - hoses need pressure testing every 36 months "until ultimate service life, if stated, is achieved". How do I check if "ultimate service life" exists? (Existing hoses were supplied with factory-new O-360A4M direct from Lycoming but can't find any limit in their overhaul manual)....
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I don't know the Lyco rules, but for RR TCM installations the maximum lifetime for hoses is 10 years. If you want to go beyond and on conditions, usually you get away with inspections every 100h or at least once a year.
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Most people are moving to Teflon hoses, these have no life limitations apart for being inspected for damage.
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Chickenhouse
That is going to be a question for my quality manager, part of the problem is going to be that the manufacturer of the aircraft has no interest in changing any of the limitations in a forty year old manual.
My suggestion would be to use the LAMP recommendations as the basis for regarding these hoses as " on condition " even if you have to back this up with a three yearly PX check.
My suggestion would be to use the LAMP recommendations as the basis for regarding these hoses as " on condition " even if you have to back this up with a three yearly PX check.
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But if you tick "Minimum Inspection Programme as detailed in the latest revision of AMC M.A.302(i)", it then says Design Approval Holder Maintenance Data (not applicable if using Minimum Inspection Programme)..........so presumably that gets you out of the manufacturers loop? When the periodic review of AMP is done (at ARC time?) the CAMO can then decide if how you are proceeding needs to be changed, or whether your "on condition" is sensible? And at the end of the day, you owner has accepted responsibility anyway.......
Curlytips,
Once you have selected the company you want to do your annual with ask them to show you the SDMP program they have in mind for your aircraft. Most engineers have already decided what they feel is appropriate for most types. You can add to it anything you consider relevant or important. Once the check is complete you will sign the declaration and it will be used to gain approval of your ARC. Publishing one on here would be irrelevant as most are based on a mixture of the old LAMP, manufacturers maintenance manual and the new Minimum Inspection Program provided by the CAA. All would be different.
One thing that seems to be causing confusion is that some people think that the CAA must first 'pre-approve' your maintenance plan prior to its use. I don't read the regulations that way and neither does my maintenance company. I have just gone through the SDMP process and the ARC has been issued by another overseeing company without a problem.
Another area of confusion is whether you still need a 'radio annual'. As I understand it if you want an avionics engineer to do one then there is nothing stopping you but if you want to incorporate a report of both ground and airborne function checks (specifying frequencies tested at what range, on what radial and at what distance etc) and incorporate that into the SDMP then it's acceptable. However it's been suggested to me that if you fly IFR then having your kit inspected by a radio engineer using proper test equipment might be better for safety and so having the traditional 'radio annual' might be a better idea.
Perhaps someone has a better understanding of what is needed regarding radios so I invite opinions on the above.
Once you have selected the company you want to do your annual with ask them to show you the SDMP program they have in mind for your aircraft. Most engineers have already decided what they feel is appropriate for most types. You can add to it anything you consider relevant or important. Once the check is complete you will sign the declaration and it will be used to gain approval of your ARC. Publishing one on here would be irrelevant as most are based on a mixture of the old LAMP, manufacturers maintenance manual and the new Minimum Inspection Program provided by the CAA. All would be different.
One thing that seems to be causing confusion is that some people think that the CAA must first 'pre-approve' your maintenance plan prior to its use. I don't read the regulations that way and neither does my maintenance company. I have just gone through the SDMP process and the ARC has been issued by another overseeing company without a problem.
Another area of confusion is whether you still need a 'radio annual'. As I understand it if you want an avionics engineer to do one then there is nothing stopping you but if you want to incorporate a report of both ground and airborne function checks (specifying frequencies tested at what range, on what radial and at what distance etc) and incorporate that into the SDMP then it's acceptable. However it's been suggested to me that if you fly IFR then having your kit inspected by a radio engineer using proper test equipment might be better for safety and so having the traditional 'radio annual' might be a better idea.
Perhaps someone has a better understanding of what is needed regarding radios so I invite opinions on the above.
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Not done it yet, but it's getting close....
Leweekend - my ARC is due in a month. My CAMO says he has another SDMP we should look at together before I draught mine, so need to go and see him!
Boeing Boy's comments re radio are really interesting. Having just had 8.33 installed and obviously checked, anything I can save is appreciated. Would love to hear comments on this matter!
Boeing Boy's comments re radio are really interesting. Having just had 8.33 installed and obviously checked, anything I can save is appreciated. Would love to hear comments on this matter!
Curly.
Unless you want to micromanage your SDMP then let the maintenance company do the hard work. You are finally responsible for your program (according to the new law) but in essence this doesn't mean you have to sit down and design a program from scratch. You will not be signing the aircraft as serviceable, just signing for how you decided it should be regarded as serviceable. The responsibility for carrying out the work and conducting the ARC is still the domain of the engineers so be guided by them.
Having had a quick look through the available guidance EASA did mention that any program should be pre approved by your NAA, however the CAA's guidance (and declaration form) makes no mention of this. After all, you make the declaration of what your program is. The person doing your ARC and the CAA have the right to say it's not good enough.
Unless you want to micromanage your SDMP then let the maintenance company do the hard work. You are finally responsible for your program (according to the new law) but in essence this doesn't mean you have to sit down and design a program from scratch. You will not be signing the aircraft as serviceable, just signing for how you decided it should be regarded as serviceable. The responsibility for carrying out the work and conducting the ARC is still the domain of the engineers so be guided by them.
Having had a quick look through the available guidance EASA did mention that any program should be pre approved by your NAA, however the CAA's guidance (and declaration form) makes no mention of this. After all, you make the declaration of what your program is. The person doing your ARC and the CAA have the right to say it's not good enough.
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Keeping the CAMO
Yes, I'll stay with my guy. After 30 years of looking after my same aircraft, he's pretty familiar and doesn't feel the need to completely take it apart every year. It's good to have an understanding about each others capabilities.......
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30 Years, thats good going. I would be interested in following this up with you once you have everything sorted. I am not using my 172d at the mo, but am looking to get it back up and running in a few months.
I was just starting to do the groundwork for a MIP for my Annex 2 aircraft (a Glos-Airtourer) when I thought to check the status quo with the CAA. Apparently LAMS remains valid for Annex 2 and there is not as yet a target date for transition to an equivalent SDMP or MIP. Thought this might be of interest..
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Now done it, and in annual at present
Creating the SDMP using template and MIP wasn't too onerous. Really a matter of understanding which boxes to tick, going through logbooks so that I could transfer AD and time-lifed items into the required annex page. Have submitted to CAMO with everything necessary (including the aircraft) and await his comments. We had discussed it before I did the final document and I believe have got it right, but everything is on a memory stick too, so if he spots something that needs tweaking, no big deal.
Saved £300 by doing it myself. Yet to see if annual cost is any less, but there are future savings for sure on certain components. CAMO was also uncertain about the need for radio annual under new rules, so I'm going to do own testing (and keep records) until someone says different.
Saved £300 by doing it myself. Yet to see if annual cost is any less, but there are future savings for sure on certain components. CAMO was also uncertain about the need for radio annual under new rules, so I'm going to do own testing (and keep records) until someone says different.
