PPRuNe Forums - View Single Post - Magneto calendar overhauls - the thin end of the wedge?
Old 10th Jun 2015, 15:24
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Perspective
 
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Interesting Leadsled re statistical differences of accident rates US to here,
You would have to get a pretty detailed breakdown I would imagine to identify
Any underlying reasons, (I know stating the obvious), lack of hours-currency? Do they include LSA in their figures?


Oh Man..this goes on and on! (I feel a collective Sigh there somewhere!)
It seems no matter what document, link or CASA reference, Reg, advisory, letter, Order or publication that gets posted here, advising, obligating, obliging, insinuating, inferring or directing you to carry out tasks I.a.w. The approved maintenance data, along with our AWI's and senior Engineers directions (and yes Brainy, correspondence) and enforcement of said Data, Regs etc, I can't believe there exists such a strong belief that the inference is that these things need not be either referred to or followed, or would not attract some legal ramification.
Put simply, if you can show me anywhere where it simply breaks down and states in clear, unambiguous black and white writing, an SB, as apposed to an MSB is approved Data, but one I must comply and one is optional, I'll send you flowers.
I can read, (barely) I know one states Mandatory and one just SB. Obviously. but the regs don't break the compliance down to anything simpler than All Approved Data.
The Mag is a bad example due to it being in and per the MM anyway.
Take for instance, as an example, just two of many directions,

1,-3.4 The procedures specified in the approved maintenance data detailing how maintenance is to be performed must be complied with when using the CAA Maintenance Schedule.

2,-6-6.1 If it is clear from the terms of the manufacturer’s requirement that the manufacturer considers compliance is optional, then that requirement is optional.

So no probs, I'll just go to that approved Data for that Piper Arrow I'm maintaining to see if they give me an option, in the Data, which I've been directed to, god knows how many times, in the Data, clear and concise please,
So I get to Paragraph 3-8 under special inspections section,

SERVICE PUBLICATION COMPLIANCE REQUIREMENTS. Piper service Publications are recommended and/or Mandatory changes to piper aircraft. "Piper service bulletins are of special importance and Piper considers compliance mandatory.

Did they mean all, some, FFS Piper!

Look for any other wording or inference in the MM for clarification, find under
General in their own Table of Insp in the sign off, general, "All manufacturers service bulletins and letters complied with" FFS.

It is clear by those two statements alone that piper consider SB"s and even SL's mandatory. They just referred to it twice, and probably more, That's in the approved maintenance Data that I have had to refer to.

Someone stated it's the Regs that seem to be unworkable, and in the current format maybe they are.
You may be a master of Law, but I find it hard to believe that when so much Wording and direction from CASA and the manufacturer, states in black and white we must use, follow and abide by the limits set out and approved by the manufacturer, that for me to knowingly not follow that is anything other than negligent.

I can take being called a muppet but find it hard to understand how one can speak from such a position of superiority and confidence and advice to non-conformance with such matters as CASA regulation, when so much Data and direction exists to state the opposite, someone even suggesting we grow some Balls. Nice.
I'm happy to talk about a common sense approach to maintenance so long as it stays within the requirements of the Regs, as they stand, as they are understood or interpreted by my delegates and as they are enforced by them,
However you want to term it.

Last edited by Perspective; 10th Jun 2015 at 15:50.
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