Originally Posted by
LeadSled
Progressive,
A comment about "servicing", so helpfully brought to our attention by CASA persons re. Schedule 8.
There is no such thing as "servicing" in Australia, just maintenance.
Doing a daily inspection is "maintenance".
Checking the oil is "maintenance". Adding fuel is "maintenance", and so it goes on.
AND --- all "maintenance" must be conducted to approved data.
Many of us have argued, long and loud, that "servicing" should be as per the FAA, which is what you are quoting, and what we had in draft regulations (Part 91/135 and 43) in 1999.
Thus, as the windscreen washing does not form part of the Manufacturer's Instruction for Continuing Airworthiness (not Servicing) there is no approved data.
This is where the ratbag Australian approach to mindless "compliance" trumps common sense, commons sense being a very uncommon commodity in Australian aviation regulation. But, of course, CASA will not even accept that the AFM, by whatever name, forms part of the certifications of an aircraft, and regularly purports to direct operators to diverge greatly from POH/AFM procedures.
If one or more manufacturer (it has always been in most FAR 25 aircraft MM) has now put said "approved data" in the MM of FAR 23 aircraft, as opposed to servicing, that is good, because it remove one item of harassment.
Tootle Pip!!
PS: Re. Jacking, way back I was only quoting the CASA "interpretation" as per the traveling roadshows, of Schedule 8, to point out the absurdities of CASA interpretations, not my reading of Schedule 8, but Conned Rod seems to have have ongoing problems with the written word.
Actually servicing does form part of the Instructions for continued airworthiness for both FAR 23 and 25 - it is an entire chapter (usually chapter 2) of the Maintenance Manual and contains among other things windscreen cleaning procedures. A quick look through some of my outdated manuals reveals it has been in Cessna MM since at least 1960 and piper since 1964. Not sure how long it is since your read an MM.
In addition as a lawyer I suggest you should bone up on CAR2A:
For the purposes of paragraph (1)(a), the maintenance data are: (a) requirements in:
(i) regulations 42U, 42W, 42X, 42Y, 42Z and 42ZA or in instruments made under those regulations; and
(ii) directions (however described) made under an airworthiness directive or under regulation 25, 38 or 44;
being requirements that specify how maintenance on aircraft, aircraft components or aircraft materials is to be carried out; and
(b) specifications of how maintenance on an aircraft, aircraft component or aircraft material is to be carried out, in documents or designs approved under another provision of these Regulations; and
(c) instructions, issued by the manufacturers of aircraft, aircraft components or aircraft materials, that specify how maintenance on the aircraft, components or materials is to be carried out; and
(d) instructions, issued by the designers of modifications of aircraft or aircraft components, that specify how maintenance on the aircraft or components is to be carried out; and
(e) any other instructions, approved by CASA under subregulation (4) for the purposes of this paragraph, relating to how maintenance on aircraft, aircraft components or aircraft materials is to be carried out.
You would be hard pressed to argue that servicing or maintenance chapter of the POH/AFM and its associated supplements did not fit under the definition of "approved maintenance data" in (c) and (d).