While we are still waiting - along with our new DAS Skates apparently -
..for the miniscule and his motley crew of discredited crats to respond to the Forsyth report HMHB brings up yet another fundamental pillar of a sound State aviation safety system i.e. AME/LAME & MROs. Perfect timing as AMROBA have recently released their November edition newsletter which gives an interesting review of the current snail's pace state of play...
First and somewhat related to Biccy's post
GA LAME NPRM
By now everyone should have read the NPRM and hopefully drawn the same conclusions. This proposal is unworkable and therefore must be rejected unless some major changes are adopted.
CASA has not addressed the fundamental problem facing the aviation industry — a clear delineation between AME training and the LAME’s responsibility.
AMROBA was involved in consultation with CASA on removing the ridiculous “exclusion” system and create a licence plus ratings just like CAR 31/CAO 100.90 series. What was not discussed is the broad based training needed to underpin this aviation industry.
What is missing in aviation today is the previous broad based AME training system that provided AQF transportable qualifications. CASA has not consulted on how this proposed AME licence and ratings will be integrated into the confusing CASR system.
Though the proposed licence and ratings, with some adjustments, will be better received by non-airline maintenance organisations, there is real concerns with what CASA has highlighted in their “Key Proposal”.
The first paragraph would mean that Schedule 6 ICAO responsibilities would be replaced by CASR 42 LAME privileges & responsibilities. Part 42 is about signing for maintenance tasks and signing the maintenance release. It is not about signing “COMPLETION” of maintenance that can be carried out by AMEs. Nor does it require “stage” inspections and completion of mods, repairs, etc. i.e. coordination.
ICAO states - “the privileges of the holder of an aircraft maintenance licence shall be to certify the aircraft or parts of the aircraft as airworthy after an authorized repair, modification or installation of an engine, accessory, instrument, and/or item of equipment, and to sign a maintenance release following inspection, maintenance
operations and/or routine servicing.”
The removal of Schedule 6 responsibilities that are based on ICAO privileges and to overcome safety related issues with maintenance records in the past is not supported.
It works and enables AMEs to perform and certify maintenance tasks and the LAME to coordinate the maintenance.
Our safety record did not come about by accident. In the non-airline sector, the LAME is the quality control of maintenance. CASA’s proposal under the CASR’s is to remove that privilege like they have done in the airline sectors.
Both EASA & FAA use the LAME (B1/2 or A&P/IA) as quality control.
And next AMROBA's take on the new DAS appointment...
:
CASA’s New DAS’s Challenges Volume 11, Issue 11
AVM Mark Skidmore has been appointed by the CASA Board for a period of 5 years. As many of our members have commented—obviously nobody in civil aviation are seen as appropriate or maybe nobody in civil aviation is willing to apply for the job. The job is not seen as attractive to overseas based ex-regulators either.
This makes 4 successive DAS that have had their base training in the RAAF with various levels of civil aviation experience. Mark Skidmore has the least amount of civil aviation experience than his predecessors. This means that he will be totally influenced by his staff in how to provide regulatory oversight, how to develop and apply the regulations and how they are applied.
Is this not the issue raised by many submissions to the ASRR?
Though hopes for the industry were positive with the election of the LNP, they actually had an aviation policy that sounded positive and the Minister introduced a regulatory review that also made positive recommendations and had industry support, many have lost the trust they put in government. Of course, the new DAS may completely surprise us.
At this stage, we do not know whether the Minister will endorse the recommendations from the ASRR Report, nor do we know when the vacancies on the CASA Board will be announced.
Neither will make much difference UNLESS the government amends the Civil Aviation Act to provide the “head of power” and direction to implement the ASRR Report recommendations.
The 3 tier system recommended in the ASRR Report, if done correctly, can return to a “rule of law” system that Australia is supposed to have.
· Civil Aviation Act—enables aviation to happen.
· CA[S]R—specifies how the legislation is applied.
· Standards—The Government gives force of law to standards, by including or referring to them in the Act or Regulations.
The question is, can the new DAS get back to a system where what the industry comply with is specified in the Act, regulations and legislative standards?
Compliance must be with the Act, Regulations and Standards NOT requirements contained elsewhere.
Most employers in our association find the regulatory system a mess, complicated and confusing that is really dependent on the interpretation of the next CASA audit team or any other CASA officer.
Can DAS Skidmore overcome the issues identified in the ASRR Report so industry can prosper?
One of the first challenges, if the government endorses the ASRR recommendations, is restructuring CASA so it aligns with industry clients. The ASRR provided guidance for a client based organisation but the “maintenance & production” sector was ignored.
The Australian aviation industry is fundamentally five major operational departments as follows:
1. Product Certification & Design
2. Maintenance & Production including training
3. Airspace & Aerodromes
4. General Aviation, Aerialwork & flight training
5. Air Transport operations
6. [Temporary] Regulatory Reform (3 years)
If the new DAS follows the intent of the ASRR, then the regulatory reform will be completed within 3 years and the individual departments would be responsible for:
A. Standard Setting including Corrective/ Enforcement Programs.
B. System Assessment including International Standards and Regulatory & Safety Promotion.
C. Entry Control including Regulatory Services.
D. Regulatory Oversight including monitoring of industry participants.
This approach is included in the ASRR Report and is intended to make the Head of each Department responsible for all aspects of their aviation sector reporting directly to the DAS.
What AMROBA would like to see is the Civil Aviation Act to be amended so that CASA would forever be client based in its structure. If the Civil Aviation Act is not amended then the next DAS in 5 years time will restructure once again.
Any civil organisation that has been restructured as many times as CAA/CASA has since its inception in 1988, would have the same difficulties as they face internally today.
By far the largest challenge facing the new DAS is the finalising of the regulatory development into a 3 tier system SUITABLE for Australia. It must place safety responsibility on the industry and remove the current micro management approach contained in recent regulations and proposals. Aviation does not need to be so highly regulated to obtain safety.
Implementing the ASRR Report Recommendations, if & when the Minister adopts, is a real challenge.
Worth a read for all aviation Small Business owners & IOS members alike is the segment under the heading -
Small Business Growth - enjoy
.
MTF...
