Folks,
Taken as a whole, this thread is a pretty good metaphor for everything that is wrong with aviation in Australia, and why it is going backwards.
NONE OF THIS "DEBATE" (if it deserves that term) WOULD EVER HAPPEN IN USA.
The FAA "rules" for continuing airworthiness are simplicity personified, compared to Australia.
The FAA "rules" for continuing airworthiness are outcome driven, unlike Australia's process and procedures driven nightmare.
THIS IS AGAINST A BACKGROUND OF STEADILY IMPROVING AIR SAFETY OUTCOMES IN US OVER 30+ YEARS, THIS LAST REPORTED YEAR BEING THE BEST YET -- THEY MUST BE DOING SOMETHING RIGHT ----- AND US GA IS EXPANDING AGAIN --AFTER THE 2008 GFC.
By comparison, there has only been minor change to Australia's air safety outcomes in the same period, what improvements there have been are largely due to the shrinking of AU GA, not fundamental improvement.
These remarks do not apply to aircraft subject to Part 145, generally but not only HCRPT and similar.
In US, the "what you have to do" is in Part 91 or Part 135,(no Aerial Work in US) the "how to do it" is in Part 43. Take the opportunity to look up the FAA web site, or the US Federal Register.
Open Part 43. Firstly count the number of page --- you can read the whole "rule" in a few minutes ---- and understand it in that time, one reading, because it is simple short, clearly written in plain English. There are ONLY 17 sub paragraphs in the whole rule, plus appendices.
Unlike Australia, it is NOT complex, convoluted, contradictory and NOT written in a style that even lawyers argue about meaning and interpretation. Understand any Australian rule in one reading??
All the detail of "how to do it" (comply with the rule) is in Advisory Circulars, again all in plain English. The heart of this part of the operations is AC43.13A & B.
Take the trouble to have a look. Many CAR 30 workshops in Australia have incorporated AC43.13A&B in their "CASA APPROVED DATA".
No such need in US, because for aircraft not subject to Part 145, there is no equivalent of CAR 30, and all the CASA bulldust, audits, NCNs etc. that goes with CAR 30 Approvals. An A&P does the work, an IA checks it out.
As I have mentioned elsewhere, all work is to ACCEPTABLE data, NOT APPROVED, with whoever is doing the work TRUSTED to choose appropriate data, not directed by FAA every step of the way. This is true across the board, including Part 145 Maintenance Organisations.
Of course, the rest of the FAA AC library, which is immense, will cover just about anything you reasonably know. ALL acceptable data.
With the FAA system, you have far greater latitude to do repairs without a FAA equivalent of a CASR Part 21M approval, and FAA still have what we used to call CAR 35 Engineers ---- but the damage or whatever must be pretty substantial to need one.
The NZ and Canadian systems substantially work the same was as US, although the Canadian system looks a bit different on the surface. The NZ system ( FAA simplified and consolidated) has been adopted widely in smaller countries.
Australian aid paid for PNG to adopt the NZ rules, because the Australian based rules were considered to no longer be workable or ICAO compliant.
Tootle pip!!
PS: FAA Part 145 and EASA Part 145 are largely harmonised, and, surprise, surprise, nothing like CASR Part145.