vee-tail-1This is getting silly. It is impossible to go back to birth with some aircraft, the documentation simply isn't there. To cross check every part and every part number would mean dismantling the whole aircraft. But paranioa seems to be gripping some MOs. Is it the case that for example: If a 30 year old spam can crashes into a school/hospital etc, and the cause is found to be something that should have been done 25 years ago. But the people who signed up the ARC are held to be liable? How could they possibly know if no paperwork was available. There has to be a line drawn beyond which no liability can be incurred, and that line is logically the last C of A inspection.
Whilst I can sympathise with you, It is not paranioa, it is the harsh facts of EASA and whilst you say how can you be held liable for what was carried out 25 years ago? well as the signatory on the ARC I and others are stating that all the inspections on the Aircraft have been carried out, failing to ensure that leaves us all open to prosecution.
One of the main problems stems from EASA's ( note the CAA have diddly squat say in it these days) intrangisence to the requirements as these have really been written in the same terms of an Airline operation. I and others are appalled by some of the content withing LAMPS, such as the requirememnts to replace seat harnesses on Aircraft such as a Cessna 150 WITH NEW every 10 years regardless of usage, the same belts installed in a Cessna 152 do not have this requirement as the manual has not been editied to include it. I do not wish to see owners have to throw good money after bad and it reflects against you as both a Company and an Individual if you are seen to be spending Customers money on items that look like new, but you have to obey the new regulations no matter how distasteful. Various lifed items may well fall under flying hours and with some items say falling at 1000 hrs or less the only way you can ascertain if these have been complied with it either to do a full search through the books or to strip as you put it the aircraft down or replace them.
BOSE X Under Part M they are only required to go back to the last CofA to ensure any work or parts applied is compliant.
Well that gets blown out of the water in the fact that lifed items will often fall out of what was the 3 yearly inspection, A company may well of happily signed out your CofA last time round perfectly legally
1, Because at that time there was no requirement to replace lifed items under LAMS
2, because items where there was a requirement to replace them were in life at that time and would be until the next Annual or C of A
Now under LAMP you have to research the aircraft back to ensure that both of the above have been complied with and now are within the current requirements, hence the need for the books.
Remember you can have your maintenance company submit their own maintenence programme for your aircraft that may remove some of this, it will then be upto the CAA/ EASA to approve it.
Remember no matter how harsh it may seem this research should be a once only thing, once done unless you change companies, it will then just need amendments as new items are added. You think I like spending 2 days of my life trawling through logbooks? I have better things to do.
So I am afraid it is welcome to EASA world I think you should all take a deep breadth, open that Copy of LAMPS that was sent to you and read the words
The owner/operator is responsible for the aeroplane’s continuing airworthiness in accordance with Part M M.A.201.
Owner/Operator Certification Statement
The undersigned undertakes to ensure that the aeroplane will continue to be maintained in accordance with the Programme, Section 3
Responsibilities and Standards.
3.1 Certifying persons must use their engineering skill and judgement in determining the depth of inspection needed and other matters,
which could affect the airworthiness of the aeroplane.
Airworthiness life limitations shall be those published by the state of design type certificate holder and supplementary type certificate
holders.
Ohh and VEE-TAIL, I wish you luck finding someone to sign your little piece of paper........... Perhaps you need to pop down to B and Q and pick up some nice white gravel to put around your plane, it will make a nice ornament on a gate somewhere, because no one will issue you an ARC for it with those constraints unless they are stupid. The one good thing though is the CAA would prosecute you too 