Part M - here it comes, ready or not
I have read this thread with great interest, not just for entertainment, but like most of us on here, this place is one of the better areas to get helpful and factual information. Our ever-helpful Civil Aviation Authority haven't been too good at disseminating information to aircraft owners/operators in recent years, especially regarding Part M Sub Parts G and I. Their standard response is still 'well, it is on our website'.
For personal and professional reasons, the 28 September 2008 will have an effect on me. As well as owning/running my own Part 145, I am also an aircraft owner.
You could be forgiven for thinking that because of my association with professional and approved maintenance, I would have all the knowledge required to move smoothly forward with Sub Parts G and I. Well, actually I am quite uncomfortable with most of it, for what I consider good reasons.
With regard to my AOC commercial customers, I feel that Part M Sub Part G is right. If you are carrying passangers for hire or reward, then the standards of operation and maintenance must be of the highest order. I have no problem whatsoever with this notion. The extra level of administration is even, in my humble opinion, justifiable, providing all EASA AOC operators are subject to the same, stringent requirements. No exceptions. No exemptions. The utopian level playing field. After all, that is what we all have been told will be happening.
To take stringent, restrictive, and financially burdonsome commercial requirements, drawn up around the airline industry, and force them onto non-commercial light aviation is not right, nor is it appropriate.
For many years, non-commercial light aviation has been maintained and certified by professional and well motivated engineers. Within an organisation, one appropriately licenced and approved engineer has been able to raise all paperwork, clear and certify that paperwork, issue a CRS, complete Log Book entries, update the history file for the aircraft, and for non-commercial 'Public Transport' type operations such as flying school aircraft, issue a Certificate of Maintenance Release or CMR. The CMR is a statement from the engineer confirming that over the last three to twelve months (as applicable) all appropriate maintenance and mandatory inspections and modifications have been carried out and complied with.
It has now been deemed that the sole certifying engineer can no longer be trusted with this responsibility. EASA wants the three tasks, a) raising and recording of workpacks and history files; b) certifying aircraft by issuance of CRS; c) issuing the CMR under a new name - Airworthiness Review Certificate; all to be carried out by three seperate individuals. And they wanted all three to be licenced engineers or graduates. This scenario is straightforward for the airlines with large admin and tech record departments.
The authority has made noisy complaints about the light aviation industry not having acted yet, being as they have had four years to prepare and apply for Sub Parts G and I. The authority hasn't, however, listened to the same industry who advised said authority that, following the fiasco of JAR's the industry would wait until the 11th hour as the authority would, without fail, move the goalposts. As we all can see following recent events, letters and LTO's, this is exactly what has transpired.
The CAA became so concerned that the industry wasn't bothering to apply for Sub Parts G and I that they even reduced the initial application fee - to £41. They have also stated that for the smallest organisations, one individual may carry out all three tasks. The CAA are making loud noises about the 160+ Part 145 Approved Maintenance Organisations that have now applied for Sub Parts G and I. The industry has told the CAA, all that is happening is organisations are merely registering an intent. If it is decided to be too administrativly and financially burdonsom, the industry will simply cancel their 'register of intrest' and write off what amounts to be less than one man-hour labour charge.
Is it too burdonsom?
From the financial point; for a small organisation, the authority will allow one person to carry out all three tasks. But because the Sub Parts G and I will be its own seperate approval, the CAA want paying for issuing and renewing this new approval. So in reality, the small organisation can continue to do what they have been doing for years, only now they will have to pay for the pleasure. The Sub Parts G and I will also have to have regular external audits in the same way as any other approved organisation, and this will have to be paid for. These costs will have to be passed onto the owner/operator. The Sub Part G, or CAMO (Continued Airworthiness Maintenance Organisation) will have to initially create a 'back-to-birth' history for each and every aircraft they will be managing. For a two-year old Cessna 172 or Piper Archer, this will be straightforward. Only most privately owned aircraft arn't two years old. How many of you have a thirty year old aircraft with only one or two Log Books going back ten years? How are you supposed to retrace the first twenty years of that aircrafts life? This initial investigation will not be cheap. Another cost to the beleaguered owner. These costs will have to be added to by ensuring your new LAMP meets the CAA requirements by the 28th of September 2008. How many owners/operators will be able to do this to the required standard without input from their maintenance organisation?
From an administrative point; there will have to be a new book raised by the Sub Part G detailing what they will be doing and how they will do it. This is similar to an MME or an MOE, and is titled a CAME (Continued Airworthiness Maintenance Exposition). This will have to be approved by the authority. The premisis for the Sub Part G, which literally can be a broom cupboard, will have to be approved by the authority. External audits will have to be responded to. Authority audits will have to be responded to. For an existing Part 145 approved organisation, this is a considerable increase in what is already percieved to be a grossly excessive beurocratic excercise which detracts from the original mission of maintenance of aircraft. This final point is seen by many small organisations as proof that light aircraft maintenance is less safe under EASA than under previous umbrellas. The stated reason for this is simple. It requires an experienced engineer to be able to deal with the ever-increasing reams of EASA generated paperwork. The more time this experienced engineer spends on paperwork, the less time he or she is able to spend on supervising maintenance. The professional and dedicated junior or less experienced engineering staff will continue to give their best, but the eye and voice of experience will not be there to advise them 'don't disconnect that yet or this will leak everywhere' or 'if you move this first, that will not get bent'. Experience isn't written down in the manufacturers maintenance manuals.
So, with regard to my earlier comment about my discomfort. After all this administration and financial cost, will any of it make your privately operated aircraft any safer? I suspect that my own personal views are sure to be echoed by many others here.
There is another point that has been brought to my attention recently by someone who has far more grasp of the whole Sub Parts G and I picture than myself.
At present, if the certifying engineer, who really is a human, misses an Airworthiness Directive or other mandatory requirement, the CAA will give him or her a hard time and advise them of the error of their ways. Official letters will be written and the lesson will hopefully be learnt.
Apparently, under EASA, if the Sub Part G and Sub Part I individual(s) miss an AD or other mandatory requirement...
it is a criminal offence.
So, following a human factors issue, a licenced engineer ends up with a criminal record. Now try and get a job in aviation with that behind you, especially in these times.
As an aside, the CAA's published list of Sub Part G approved organisations makes interesting reading, if only for the wrong reasons. Two thirds of the organisations presently approved are approved for either turbine aircraft or helecopters only.
Well, after digesting the above, how many of you will move across to the LAA or 'N' reg before January 2009? How many of you are going to be stuck with type certified 'G' reg aircraft that you can't sell and are too expensive to maintain? And how many of the Part 145's will actually follow up their 'register of intent' and gain Sub Part G approval?
Oh, forgot to mention, I haven't applied.
And, most importantly, do remember. A Continued Airworthiness Maintenance Organisation has absolutely nothing to do with maintenance. It is only an administrative organisation.
Real maintenance is carried out by engineering staff in a MAINTENANCE ORGANISATION such as an M3 or a Part 145.
camlobe