I think it is mischievous to try and read rules in isolation. You need to know the whole package. This is where I have seen so many guys get it wrong over the years.
I have never worked as a regulator, well not at least in the civil environment. The LAME is not a policeman or even a judge. The problem we have though is both of those groups have real strange interpretations of how things are done.
Something similar happens when the regulator does an audit of the facility.
If we look at Item 12 on the list for example. Refitting a plug.
The way the work is judged during audit is the publication, do you have the latest and relevant acceptable data for the torque figure. Is the torque wrench suitable and is the calibration chart current.
You would be expected to have the correct anti-seize compound and new or annealed gaskets.
We all know the regulators have different personal opinions and understandings. It is difficult to get a straight answer at times.
When you ask how the owner is supposed to manage a task such as cleaning a plug the reply is often 'ensure they have the correct publications and calibrated wrench'.
That may sound completely impractical but that is what these guys assume. The certification is signed signifying that the work has been done correctly !
The owner would have difficulty fitting a new part legally, well in compliance with the full rule package that is. Unfortunately for us as GA type operators the rules are covering a very wide range of aircraft maintenance activity.
The guys in the hangars have no trouble working to the rulebooks, the hangar protocols and procedures are such that the system just works.
They are working on privately owned, club and RPT aircraft as part of the daily mix.
If we just concentrate on privately owned for this conversation though we can then look at owner maintenance and parts supply.
The owner needs to have an overview of the regs and various rules. Tying to read each clause will just be misleading.
I mentioned the words 'Gist' and 'Vibe' earlier in this thread.
When you look at the owner maintenance list you have to wonder.
Can't jack the aircraft.
Can only replace defective lockwire ! ( Well I guess it would be if someone cut it).
Can only repair a tube, not replace.
Same with wheel bearings, service but not replace.
See how the filters are different, an appropriately skilled owner may CHANGE them.
We don't see that word often.
OK, given that an owner can't fit new items like tyres and bearings then what are the chances he can fit a new battery, seatbelts or side windows ?
I don't have a problem with a skilled owner doing whatever he likes to his aircraft. He owns it and as far as I am concerned he can do what he wishes.
That seems fair.
The only times I am concerned if he then involves me or my signature...
Changing the status of something when it is still showing against my signature gets my attention.
If he removes and refits wheels and there is no new certification then obviously there will be words.
The owner must realise he is potentially setting the maintainer up by not getting into the swing of things.
The other times I may get involved is if the aircraft rocks up with unrecorded maintenance and the owner expects an annual or 100 Hr or similar done.
Where do you start there ?
If it had new windows, for example, then I guess the easiest path would be to convince the owner he has to sign the RTS log entry himself. The alternative would be to remove and refit them properly, yet another job getting done twice.
Is replacing a side window the same as changing one ?
How about a towhook, a lightbulb, or a seatbelt.
Did I say the Aussie regs are not the flashest when compared to the NZ and FAA versions ?
Last edited by baron_beeza; 3rd Sep 2015 at 23:26.