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Old 1st Dec 2017, 04:33
  #173 (permalink)  
LeadSled
 
Join Date: Jul 2001
Location: Australia
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down to a simple question on serviceing and maintenance.
ConnedRod,
Actually, I could reproduce a paper on this subject, but it is too long for a pprune post.

Suffice to say, "maintenance" is defined in the Civil Aviation Act 1988" (the ACT).

It is not further defined in the Civil Aviation Regulations 1988 (the CARs)

"Servicing" is defined in the CARs, and specifically excludes anything that is defined as maintenance.

As far as I can see, neither is further defined in Civil Aviation Safety Regulations 1998 (CASRs), including the Dictionary.

Let me make it clear, I support the US approach, where the differentiation between "maintenance" and "servicing" is clear.

Just one example, fueling is defined as a maintenance task in both Schedule 5 and Schedule 8 of the CARs, and within any reasonable interpretation of the definition of maintenance in the ACT.

Therefor, it cannot be "servicing".

Fueling is included in various CASA publications, like a previously mentioned CASA AWB on "servicing", (which looks like it has been copied from US sources, regardless of Australian legislative differences) , where many items on the "servicing" lists, including fueling, are clearly not "servicing". but maintenance, under Australian legislation.

All the US POH/AFMs, etc are produced against a background of the US legislation, not Australian, but CASA resolutely hold to the position that only Australian legislation applies to a VH- (or other Australian) aircraft.

Therefor, the CASA position, which I don't like, is that, where ever there is a conflict, the Australian legislation prevails, and many things that US may publish as "servicing", are in our system, maintenance, and subject to who can perform that maintenance.

It is an understatement to say that the aforementioned AWB on "servicing" is misleading.

Then there is the can of worms of what is and is not "approved data", again the US system of "acceptable data", a far more efficient and less litigious approach, as is the whole US system.

As to what is "mandatory", it is a simple fact that a number of publications (SB/AC/AWB) depending on context, may constitute AN acceptable means of compliance (AMC- a term universally - I hope - understood) but they are never mandatory or "the law".

This is a simple statement of fact, no matter how devoutly some of you believe otherwise, or how contemptuous our mate Conned Rod is of pilots, because we just "buy" our jobs.

Perhaps we should consider whether a LAME is really an "engineer" at all, rather than a mechanic, engine fitter, sheet metal worker, painter, electrician, whatever. The inescapable fact is that a LAME is a tradesman.

An "engineer" is somebody (to simplify it) who is qualified for some level of membership of the Australian Institute of Engineers, or a similar body, which usually, but not always, means at least an undergraduate degree in the discipline.

Tootle pip!!
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