AD-ENG-4 under attack.

[Bob Murphie]

AOPA spokesman advises;

“I advise that we will this week submit to CASA to cease all unique Australian AD".

One supposes this includes AD-ENG-4 which allows many Australian aircraft in the private category to keep flying after the manufacturers recommended TBO and the imposed 12 year life span but subject to periodical inspections.

Notwithstanding the possibly overall good intent of the action, the removal of this AD will impact greatly upon many private operators.

[flyitboy]

Now this could prevoke a millions thread responses, & I hope it does.


F

[Bob Murphie]

Here's another one from the same spokesman;

"Let's get some comments in and see how many others cannot comprehend the place of AD ENG4 in stuffing GA".

This bloke wants to repeal the AD, (because it's peculiar to Australia), but can't comprehend repealing it would send us back to the prescriptive days.

It does not bring us in line with the US recommendations.

[porch monkey]

Ever heard of "Be careful what you wish for" ? Some people just don't get it.:(

[Walrus 7]

Hello, Bob.

Did the AOPA spokesperson give any indication why they consider that AD-ENG-4 is "stuffing GA"?

What are the chances of CASA stopping Oz-only ADs anyway? This is all a reaction to the legendary "3000 planes" AD of a couple of weeks ago. CASA did themselves no favours with that one.

Walrus

[Bob Murphie]

Yes mate he did, but I am still working my way through the convoluted details. He is quoting some amendment 7 not inclusive of the amendment 10 which is curently in fashion. Also he is orientating in time and space with turbine vs piston aircraft and PVT and AWK vs paying pax. He branches out into test bed cells for overhauled engines which are not the subject of the AD.

I can't talk with the man or the organisation, all who see any one that opposes or questions their ideas as hostile and open to ridicule and attack. I must admit I give some stick as well, so perhaps you can broker a deal to at least simplify or civilise the matter at hand.

I can see where he is coming from but can't see an alternative if they manage to have the AD "repealed". The way I see it things go back to how they were before. ie. the prescriptive 2000 hrs or whatever or 12 years which ever comes first. Mention is made of a $20,000 overhaul. Struth, when did he last get an engine overhaul.

My late legal advice is that the previous status is no longer there because of the AD, BUT this doesn't necessarily mean things automatically revert to the US "recommendations".

Other advice from within the fortress Canberra mention things like "over my dead body" etc. I think this gives an indication of the chances of success. Give Office of Legal Counsel a buzz, they are always helpful with honest and simple advice.

At this stage one should consider the oft used phrase "if it ain't fkuced, don't fix it".

I don't understand what motivates CASA "spokesmen" to manufacture statements like the 3000 grounded aircraft. I am beginning to believe they are trying to kill GA in this Country.

Remember, just because your paranoid doesn't mean they are not out to get you.

[ForkTailedDrKiller]

My LAME was warned by CASA a month or so ago that this was coming. The next 100 hrly on many aeroplanes could be VERY EXPENSIVE!

Dr :8

[CHAIRMAN]

Am I missing something here? - there is a difference between recommendations and AD's - there always has been, hasn't there? I can't see the leap between cancelling unique Australian AD's, and then doing anything different to what the US does.
What will be the difference?

[Chimbu chuckles]

Indeed. OEM TBOs are recommended in the USA.

The only way this could be disastrous is if manufacturers decide to change recommended to mandatory TBO. I think that would cause an absolute uproar in the US and their politically savvy alphabet groups would surely knock it on the head as 'unconstitutional' or some such.

The basic fact is that the most dangerous period from an engine failure point of view is the first 3-400 hrs post overhaul/from new. If the engine is running fine at 1700 hrs it likely will be at 2400 hrs.

In the end though I suppose most GA engines are not doing the annual hours that helps ensure trouble free running post TBO. That is a double edged sword too....low utilisation is likely to mean the engine has been topped pre TBO...which means the engine is even MORE likely to be safe beyond TBO.

Lets face it, the bottom ends are pretty bullet proof.

Are we facing a situation where fear of litigation is negating the very design basis of the engines where individual parts can be exchanged as needed, cylinders, valves, magnetos etc, rather than overhauling the engine just because a date or time in service has arrived?

I overhauled my IO550B at TBO+ 10% and did so with a heavy heart as it was running like a swiss watch. Had I known then what I know now that engine would be 400 hrs past TBO today and likely still running strong. The cylinders only had 800 hrs (the engine had been topped long before I bought the aircraft) in service when I pulled them during overhaul and replaced them with new Millenniums. The bottom end/crankcase are as delivered from the factory, merely checked and found to be within tolerances and reinstalled:ugh:

Or are we dealing with a meddling moron?

[T28D]

Chimbu you got it in one a meddling moron.

[Walrus 7]

To try to simplify matters, can someone check that I have this right.

1. Everyone is concerned that if AD-ENG-4 is repealed, no-one will be able to run engines on condition anymore.

2. AOPA wants all Oz-specific ADs repealed and FAA and manufacturers' recommendations used instead.

3. AOPA contends that AD-ENG-4 isn't needed anymore because the ability to run on condition is enshrined in CAR42B, which takes precedence over AD-ENG-4.

Have I got that straight?

Walrus

[Bob Murphie]

Walrus;

1) That IS what I am concerned about.

2) The FAA AND manufacturers don't make recomendations, the manufacturers say hard time no extensions, zero full stop.

3) My last maintenance release notes the following;

Schedules/System of Maintenanceapplicable to this aircraft= CASA CAR 42B Maintenance schedule 5 (which is the system of maintenance for the aircraft periodical), and AD/ENG/4.9 Appendix "A" which is for the engine. I don't follow how CAR 42B takes precedence over AD/ENG/4.

Have I got that right?

[Walrus 7]

Why is it that dealing with CASA documents is like trying to solve the riddle of the Sphinx (which has been solved but it took hundreds of years)?

The way I read it is that CAR42B does include the engine (as noted in AWB 85-004 Par 3) and that AD-ENG-4 specifies a schedule of condition checks. Therefore, if we obsolete AD-ENG-4, all we lose is the schedule of checks. The impact of this would need to be taken into account.

So, am I getting close?

Walrus

[Bob Murphie]

Facts as I recall are;

1) Prior to ED/ENG/4 amendment 7 there were NO on condition piston engines. All were specified in ANO's as hard time overhauls.

2) Engine manufacturers recommend fixed times.

3) The airworthiness bulletin has dubious legal ramifications (still checking), to make engine extensions. CAR 42B does and always has had engine checks as part of the system of maintenance and in the case of schedule 5 is the CASA schedule. All piston periodicals I have had anything to do with included spark plugs, oil filters etc. AD/ENG/4 is the instrument that extends hard times to on condition subsequent to condition checks including oil uptake etc.

I fear that to obsolute AD/ENG/4 would take us back to some obscure ANO and fixed hard times between overhauls.

Why not just leave this one alone. I refer you to your own first paragraph of your last post.

[nomorecatering]

How do insurance companies handle engines that are running fine on condition but past the manufacturers recomended overhaul time.

What if your TBO is 2000 hrs and you are on condition at 2500 hrs and have a failure. Do the insurance companies have grounds for denying a claim?

[T28D]

No More Catering

AD eng 4/7 is an alternate system of maintenance available to operators of piston engines beyond TBO and or Calendar renewal time limits only private and airwork.

It is not a casual tick and flick thing, there are substantive reqirements in the AD to make sure the LAME and C of R holder are acting responsibly.

Yes the aircraft is insurable, which is quite different from the issues in the adoption of the FAA Manufacturers Recommendation position.

It is all but impossible to insure an aircraft in the US operating beyond Manufacturers recommendation for public liability that will allow operation into a mainstream FBO airport.

It is a legal fact that if you go outside manufacturers recommendation for ANY product at any time you void any liability the manufacturer has in respect to operation of the product, servicing of the product and warranties that may have been in force over the product. You are on your own.

In the Aviation case in Australia the adoption of AD eng 4/7 allowed operators to continue to use their aircraft legally beyond TBO and time limits within the Aviation Regulatory framework. A quite unique set of circumstances comparitively world wide.

We all need to be careful what we wish for, change for the sake of change is rarely a good thing, old aviation saying,"If it aint broke, don't fix it", meddling with this AD is fraught with the potential to create a regulatory nightmare and real danger of substantive cost penalties on Airwork Operators putting a lot of Flying Schools out of action.

This issue is not just about Insurance, nor is it operating "on the cheap" AD eng 4/7 was negotiated responsibly by folk who knew what they were doing and it has operated successfully for a long time with a very good history of outcomes.

[Trash Hauler]

Why don't some of those bureaucrats learn what risk management really means?


My understanding from the thread is that AOPA is the one trying to mess with this.................not the bureaucrats.

[PlankBlender]

How about a friendly letter to AOPA management, pointing out that the interests of pilots and aircraft owners may be better served if they used their resources to fight for better T's&C's in the current employment market, rather than trying to fiddle with minute details of technical regulations??? :ugh:

[Bob Murphie]

Priorities;

There is a conundrum.

Pilot Unions would argue over the fact that AOPA originally stood for aircraft owners and their pilots. More recently after having lost the majority of the owner group, possibly and probably as a consequence of "CASAGATE" they now need the pilot group which are divided around the numerous Unions and other alphabet soup mobs. Although the AOPA spokesman does assert they represent of all GA?

To be fair, they did attempt to support entry level pilots to the system, but once the students were out of the melting pot they, (the students), went their own predictable way.

Too many fish and chip shops in the same street now catering for some 20,000 Aussie pilots.

[T28D]

Bob, The real problem is not AD eng 4/7, the problem is meddlers who play at being regulators without sufficient knowledge to understand the need to leave well alone.

[Bob Murphie]

AD/ENG/4 has "NEVER" been a problem since it's common sense application.

The removal "COULD" be a problem- Anyone who gets delight in change for the sake of change, especially where CASA is involved, probably, and more likely, is a sinister CASA "plant".

[Bob Murphie]

You are right, but to give credit where due, CASA had been embarked on a process of eliminating Australian peculiar matters for some time.

AOPA have supported the concept until this "spokesman" came to notice.

This particular attempt at amendment is simply not in the best interests of the shareholder/members of the particular company.

I have a Commonwealth Ombudsman's report at hand that states as to schedule 5, that assert...

This schedule is the CASA schedule of maintenance, not any manufacturer's.

There is an option for the manufacturers schedule.

I also smell a rat.

[the wizard of auz]

Hear hear Plankbender. :D:D
I agree whole heartedly, as would many others who operate on the AD.ENG. 4 system.
I had three Engines on the system and no problems to date. one of the engines went to nearly three times its recommended life without a problem, before I changed it out. when stripped for examination,. almost all the components were within limits. the few that weren't were non critical components and were still servicable.

[Jabawocky]

5000 hrs on a piston eng hey Wiz?

Just getting run in dat wun!

J:ok:

[Trash Hauler]

I seem to remember when Schedule 5 first appeared that it was intended as a schedule for those aircraft whose manufacturers did not specify any maintenance schedule or the maintenance schedule was inadequate (eg. Tiger Moth).

I cannot recall (at initial release) if an owner could elect the CASA Schedule 5 in lieu of the manufacturers schedule as a simple choice - eg. it suits me better to use the CASA schedule as it will cost less etc.

Does anyone remember at what point schedule 5 could be selected in lieu of an adequate manufucturers schedule? Do you think AOPA's drive for to rid us of Australian unique ADs would extend to Schedule 5 as well?

Cheers

TH

[the wizard of auz]

5000 hrs on a piston eng hey Wiz?

Actually, it was a little over that. replaced one cylinder, due to a broken ring, and while I had the engine in bits I did the rings in the other cylinders. that was at about 3600Hrs TSO.
was still going strong when I stopped operating it with all the comps in the high 70's, (78 average) about 2 Ltrs of oil in 100Hrs and fuel burn unchanged.
Just have to love the 0320D2J. was thrashed as a mustering machine for nearly all those hours too.

[LeadSled]

Folks,

Schedule 5 is the equivalent of FAR 43, Appendix D, indeed it is a copy. As happens all to often, a few Australianisms were added, inc. para. 2.7, which costs GA dearly.

Schedule 5 is only an inspection schedule, you still need the data, but the MM for most GA aircraft are not comprehensive, you still need additional data. Despite some CASA AWIs not being able to comprehend this little fact, and insisting that any MM is all singing all dancing.

For example, the "data" for corrosion detection and rectification will be found in the relevant FAA AC. See below, FAA AC43-13A/B are now acceptable data, without "CASA approval", or any charges. AC 43.13A/B is the "bible" (except that its a lot bigger than the bible) for maintenance of continuing airworthiness for smaller aircraft.

As a result of CASA Instrument 377/06, CASA is out of the "approved data" business, and aircraft registered operators now have the same choice of data as if you were maintaining an aircraft under FAR 91 and FAR 43.( or JARs for that matter) --- with no CASA charges.

You have CASA's Greg Vaughan to thank for this, but para: 2.7 has got to go, and when it does, it will probably halve Hangar Keepers Liability insurance.

HooRoo for now!!

[Bob Murphie]

I think your reference now makes it mandatory to "guarantee" the airworthiness of the aircraft until it's next periodical? (Even pink slips in NSW are only good for 14 days).

Except for an arse covering exercise by CASA over schedule 5 perhaps?

Pray tell, para. 2.7 is exactly what?

Whatever, it appears that "hard time" engine maintenance will be the new "recommendation" and dissolving AD/ENG/4 makes even less sense to aircraft owners and subsequently, operators etc.

Edited to add and remove some incriminating comment;

About 1996 I argued a case that culminated some time later with a Commonwealth Ombudsmans investigation into a "dodgy" MR and with subsequent apologies from Director of Aviation Safety with a promise to alter things.

The then Chairman of the CASA Board invited me to help compile a "Guide for the purchase of a light aircraft" which the AOPA office holds for distribution to those that want it. (if they haven't shredded it).

My "guide" was a rewrite of schedule 5 which at the time was one of the maintenance options open to an owner and gave the onus of responsibility by the LAME of the inspection to he, (or she), who commissioned the inspection. NOT the purchaser.

It now appears that schedule 5 removes the onus of responsibility from the Certificate of registration holder (or the operator), to the LAME to warrant the inspection until the next periodical. Tyres brakes come immediately to mind.

Reflecting on events;

1) CASA told me that schedule 5 made redundant the requirement for 4 yearly "major inspections" because things would be inspected annually therefor a better system.

2) Schedule 5 was a system of maintenance given as an option to the manufacturers system and at the time seemed a better idea because the manufacturers were probably only out to make a quid from their products?

3) Schedule 5 is now NOT a sysyem of maintenance in lieu of the manufacturer, but ONLY a schedule of maintenance.

I still can't see how repealing AD/ENG/4 makes any owner's life easier. The insurance implications as discussed shove everything back on the owner operator anyway.

As Bart Simpson said, I can't but half feel respsonsible for this.

Can anyone tell me exactly when para 2.7 came into existence?

[Trash Hauler]

CASA Schedule 5: Para 2.7


Unless otherwise indicated in the table, where the table requires a thing to be inspected, the inspection is to be a thorough check made to determine whether the thing will continue to be airworthy until the next periodic inspection.


(see the regs (http://www.casa.gov.au/download/act_regs/1988.pdf))

[Bob Murphie]

Trash Hauler;

Thanks for that info which after reflection prompted me to edit my post.

It pushed it to the back of the thread however, so if you feel the urge, see my edit above.

Cheers.

[Trash Hauler]

Bob,

I am with you on AD-ENG-4. I cannot understand any benefit to aircraft owners if this was repealed. I think the dogma AOPA are on re Australian unique ADs misses the point in this case.

I do believe though there are LAMEs out there who would sleep better at night if AD-ENG-4 was repealed. As they sign out for another year an engine that may or may not go the distance some wonder who is liable if the engine fails in that period.

Cheers

TH

[Creampuff]

Bob

Paragraph 2.7 has always been in Schedule 5.

Schedule 5 was added to the CARs 17 years ago. (see: http://scaleplus.law.gov.au/html/numrul/10/5257/0/NL000530.htm)

Here's how to join the dots between a bugsmasher and Schedule 5: REG 41

Maintenance schedule and maintenance instructions

(1) The holder of the certificate of registration for a class B aircraft must ensure that all maintenance required to be carried out on the aircraft (including any aircraft components from time to time included in or fitted to the aircraft) by the aircraft's maintenance schedule is carried out when required by that schedule.

….

REG 42B

Maintenance schedule: CASA maintenance schedule

(1) Subject to subregulation (2), if:

(a) the holder of the certificate of registration for a class B aircraft that is an aeroplane has elected to use the CASA maintenance schedule for the aircraft's maintenance; and

(b) the election is in force;

the aircraft's maintenance schedule is the CASA maintenance schedule.

(2) If:

(a) a person has elected to use the CASA maintenance schedule for an aircraft's maintenance; and

(b) a turbine engine is included in the aircraft;

all instructions issued by the manufacturer of the engine for the continued airworthiness of the engine are to be taken to form part of the CASA maintenance schedule and the election has effect accordingly.

[Creampuff]

PS: You're naughty, Leaddy.:=

You said:Schedule 5 [of CARs] is the equivalent of FAR 43, Appendix D, indeed it is a copy.[my bolding]

There is nothing in Schedule 5 of CARs (here: http://scaleplus.law.gov.au/html/pastereg/0/51/1/PR007210.htm) that is 'a copy' of anything in Appendix D of FAR 43 (available through: http://www.faa.gov/regulations_policies/faa_regulations/)

You sure you've read both, big fella??;)

[Bob Murphie]

Creampuff;

My hard copy at hand of Commonwealth Ombudsman report into matter CASA and Murphie following complaint to CASA dated 7 October 1996 and investigation started 17 May 1999 states in concurrence with you;

"The COR holder may elect whether the maintenance is done in accordance with the aircraft manufacturers schedule or Civil Aviation Regulation (CAR) Schedule 5 unless there is an approved system of maintenance in force".

"on completion of the work, a LAME issues a maintenance release which is in effect certifying that those parts of the aircraft inspected will remain airworthy for the next 12 months or 100 flying hours, whichever comes first.

As previously mentioned I did a rewrite of schedule 5 (note amendments to prior posts which mentioned in typo schedule 4), which was commissioned after urging by the then Chairman of the CASA Board of Directors.

It was never published by CASA because of an obvious admission of liability on their part. It was passed onto AOPA.

Nowhere however, does schedule 5, as it's alternative to the manufacturers schedule, mention extending aircraft engines on a conditional report.

This is the function of the AD/ENG/4.

Prior to ED/ENG/4 amendment 7 there were NO on condition piston engines. All were specified in ANO's as hard time overhauls.


The Commonwealth Ombudsman report concluded in recommendation 3: "CASA to consider the accuracy of its advice about the suitability of CAR Schedule 5 and:

(i) Take any necessary appropriate action and,

(ii) advise Mr Murphie of its final position in regard to CAR Schedule 5.

Except for a "lame duck apology from the then Director of Aviation Safety, a thorough ringout by various Parliamentary Secretary's, I have had no further personal advice of definitive statements of changes.

It's been a long time between beers Creamy.

[Creampuff]

Don't worry Bob, the new regulations will be out soon, and it will all become clear and simple ……

[LeadSled]

Creamie, old mate,

Perhaps I should have phrased it a little more accurately:

Schedule 5 is and was based on and closely aligned with FAR 43, Appendix D.

Appendix D to Part 43—Scope and Detail of Items (as Applicable to the Particular Aircraft) To Be Included in Annual and 100-Hour Inspections

Plus the Australianisms, including the nonsense of para; 2.7.

Our yank mates have always managed to be more economical with words, and strangely enough their aeroplanes don't seem to fall out of the sky any more often than in Australia., indeed the opposite is the case --- have a close look at the raw NTSB v. ATSB data, and compare like with like.

Indeed, unbiased comparisons of the statistics suggests there is no correlation that suggests "more regulation = more safety"..

Although I must say, sitting through some of the consultative meeting, one could be forgiven for thinking that even those in sectors of industry are wedded to the idea that:" The greater the cubic volume of regulation, the greater the cubic volume of air safety". This notion is closely allied to the often voiced demand that we formulate regulations to control "perceived safety problems", even when the most diligent research can not show any link between the "perception of a safety problem" and the real world existence of the claimed critical aviation safety problem.

See the PCR Report and recommendations for regulatory change to address a "safety perception".

But!, Hey, "It stands to reason that more regulations will increase safety", a statement actually made in public, with many witnesses, within the last 21 days.

As the common CASA press release so often says :" More safety for xxxxxxxxx", fill in the name of the next place for safety seminar, and I keep having this crazy vision of somebody marching in with a whole bunch of boxes of "more safety".

Where, in these "more safety seminars" you can learn that you can "repair" a tyre's tube under Schedule 8, but not replace it with a new tube.

To avoid committing a serious strict liability offence, a breach of the Act, even, you should probably clean and repack the wheel bearing blindfold, to avoid looking at the condition of the bearings --- because that's an inspection, not authorized by Schedule 8 --- inspection is secret LAME business.

The one that always grabs me is:13. Replacement of batteries., which, to a simple fella, seems to suggest that Schedule 8 allows replacement of a battery. But as our ever diligent protectors of us from ourselves, and purveyors of "more safety" so carefully and condescendingly explain, this piece of rocket science requires, as do all maintenance tasks, CASA approved/approved/acceptable (take your pick) data.

Low and behold, all is revealed, every aeroplane battery manufacturer's data requires the battery to be "fully charged" before installation, and that requires a CAR 30 approved workshop plus "approved charger".

As for that hardened criminal element in aviation, who use solar powered trickle chargers on parked aircraft, cease and desist, unless the said charger is "approved" and is only being used pursuant to a CAR 30 approval. You wouldn't be so criminally inclined as to use on of those dinky little solar charges available in most pilot shops, would you?? You know the ones, they plug into the cigarette (sorry, Power Receptacle) lighter plug.

All you blokes and blokesses who routinely cleaned fouled plugs (a common enough byproduct of using 100LL in engines designed for 80/87) don't let me catch you using a Torque Wrench that doesn't have a current calibration test certificate ---- you all do use a torque wrench don't you? Just like your friendly family LAME, when he, she or it (my best non-discriminatory, non-sexist style) replaces a spark plug??

So, all you cowcockies who have a flat tyre or flat battery on the C-206, out the back of the machinery shed at Upper Binglebunglebone Station, your nearest LAME is only 500km away, resist the temptation to commit another blatant criminal offense.

Tootle pip!!

[Justin Grogan]

http://www.casa.gov.au/media/gallery/images/sm-byron.jpg

"It’s totally inappropriate for government agencies like
CASA or the ATSB to develop a framework, a rule
system for working, put it into a publication, hire a
bunch of people, and leave it for 20 years and keep
doing the same thing."

[Creampuff]

Such terminological inexactitude is disappointing, Leaddy.

As to the rest of your post, you have a (typically) pilo-centric and (typically) dangerous perception of how 'simple' aircraft maintenance is. Would you really fit spark plugs to an aircraft engine without using a calibrated torque wrench? LAMEs might do it, because they have done the job so many times that they have 'calibrated wrists'. But anyone else? You're joking, right?

Are you sure you understand the intricacies of proper battery maintenance?

How many people do you know who've been prosecuted for committing the offences you have identified? To the nearest 10 will do me.

[Bob Murphie]

I know a bloke who was threatened with a show cause notice for having a tyre valve cap missing. Could possibly have fallen off in flight. The fact that he had a plane load of Magistrates on board to witness the bastardry held the balance of power in his favour.

I think the operative word here is "COULD" especially if "they" are out to get you.

[Creampuff]

I'm not interested in administrative action that was threatened.

I want to know how many people have actually been prosecuted for doing the things Leaddy has identified as offences.

[tipsy2]

Creamy, actual prosecution MAY be avoided by the use of a threat (to prosecute). That is of course a sleazy cheats way of obtaining compliance that yes I have directly witnessed.

I took the appropriate action (and avoided any involvement of the legal fraternity) under the circumstances and then had the particular officer 'removed'.

No names or the circumstances will be mentioned, I still to this day cannot believe the pettiness and the ultimate stupidity of the officer concerned to have even embarked on the course he chose.

tipsy:=

[Bob Murphie]

Creampuff;

I say again, "COULD" is the operative word here in the AD/ENG/4 matter and LeadSled's illuminating highlights.

You are as aware as I, of what CASA "could" have done to save me bundles of money with regard para 2.7 but a lot ignored the FACT in the name of "cronyism".

A CASA counselling session does not, a safety redress make.

NOTE;

"The Commonwealth Ombudsman report concluded in recommendation 3: "CASA to consider the accuracy of its advice about the suitability of CAR Schedule 5 and:

(i) Take any necessary appropriate action and,

(ii) advise Mr Murphie of its final position in regard to CAR Schedule 5."

I am miffed about this miscarriage of ignored proceedure and It "COULD" have been addressed, and I still await CASA's response, but the maintenance releases are still being signed out with the corolory of a carbon copy of my near death experience.

But who cares, it's only administrative action?

[LeadSled]

Creamie, Old Mate,

Actually, in my case I have not one, but two W&B torque wrenches, and yes, they do have calibration certificates issued by a CASA approved org., plus gap guage, gap tool, thread cleaner and thread chaser, plus approved thread lube. Even a Champion socket and 12 pt. open ring spanners for the plug body and the proper fitting of the lead. And they go everywhere with me, along with the rest of the servicing (not a CASA approved term, it's all maintenance) kit.

How's that grab ya!!

And I will bet my "calibrated wrist" to produce 32-36 ft/lb. (see Wright/ Lycoming/ TCM Continental for correct data for engine type) against any LAME, but that is beside the point, I am unaware of any exemption to allow the use of 'calibrated wrists'.

Don't kid yourself about the "Magic of Maintenance", with few exceptions, CAR 3/FAR 23 aircraft are crude devices, with engines of about the sophistication of the Grey Fergi tractor, with one notable exception, at least the Fergi has got a manual spark advance.

As for battery maintenance, are you referring to open lead/acid, sealed lead acid, gel/cell or nickel/cadmium, I would be happy to supply you with the data, if you have a need. I use examples of each.

Ain't life grand!!

Tootle pip!!

[bushy]

Most of the rules and regulations, maintenance schedules, orders, etc are really there to protect people who are not in the aeroplane. CASA is there to protect the government from any legal challenges arising from aviation.
There are many contradictions and vaguaries. CASA seems to have set itself up as the source of all knowledge, superior to all manufacturers and engineers.
CASA has decided that the PA32 must have wing spars replaced after 11000 flying hours. Nowhere else does this happen. Piper recommends an inspection at 70,000 hours (yes seventy thousand hours), and they have a scheme for this inspection. CASA will not even accept this Piper inspection scheme.
I have serious doubts as to CASA's motivation.

[Creampuff]

Oh I see, Leaddy.

You have and use:W&B torque wrenches [that] have calibration certificates issued by a CASA approved org., plus gap guage, gap tool, thread cleaner and thread chaser, plus approved thread lube. Even a Champion socket and 12 pt. open ring spanners for the plug body and the proper fitting of the lead.So when you said:All you blokes and blokesses who routinely cleaned fouled plugs (a common enough byproduct of using 100LL in engines designed for 80/87) don't let me catch you using a Torque Wrench that doesn't have a current calibration test certificate ---- you all do use a torque wrench don't you?you weren't actually suggesting that the requirement to use a calibrated torque wrench is silly and unnecessary.

You understand the intricacies of battery maintenance, so when you said:As for that hardened criminal element in aviation, who use solar powered trickle chargers on parked aircraft, cease and desist, unless the said charger is "approved" and is only being used pursuant to a CAR 30 approval.you weren't actually suggesting that there's no risk in trickle charging any battery for long periods.

I think I now know what you were trying to say ……. I think …. You weren't actually suggesting there's no valid technical basis for these requirements … were you?

By the way, how many people do you know who have been prosecuted for not using a calibrated torque wrench, or for using a solar trickle charger? As I said, the nearest 10 will do……

[LeadSled]

Creamie, Old Mate,

My personal position is: If you don't know how to do the job (and that includes the right data and appropriate tools) don't. If you have any doubts about your capability to do the job, don't. And if it is an aeroplane, not a motor car, make certain the MR or aircraft logs books correctly reflect what you have done, don't give CASA a free kick.

P7 is not confined to flight operations, for those of you who don't subscribe to P7, you should; Prior Planning Prevents Piss Poor Performance. Why's it called P7, I don't know, either, maybe the guy who invented it couldn't count, or maybe it should be Proper Prior etc., etc.

A comment on batteries: I personally don't like the idea of charging batteries in a stationary aeroplane, no matter how small the trickle, and no matter how smart the microprocessor program, even if FAA have no objection. I can't personally go along with the idea that there is not at least a small amount of some highly corrosive gas about, and it won't be carried away by the battery box vent.

The best place to charge a battery, clean it, dress the terminal and generally get rid of all the dirt and worse is clear of any machinery. There are some very good chargers available, but they do not include the $20-30 or so units from auto stores.

All the battery manufacturers we are interested in here have good web sites, getting "the acid" on good battery maintenance, and the right charger characteristics, are no further away than your computer.

As a matter of interest, some of the best chargers to meet the battery manufacturers recommendations for maintenance charging are in boat shops.

And, folks, please, please, please always wear good safety glasses when you are handling a battery, the liquid contents and your eyes mix all too well, to the very great detriment of your eyesight. Murphie's law is merciless.

Sadly, some of the worst examples of "assault n' battery" will be found in "fully approved CAR 30" hangars.

A bit of a long way from AD/ENG/4, but what the heck.

Tootle pip!!

[Creampuff]

I'll take that as a 'no' and 'zero', Leaddy!

To get the thread back on track, what will happen if AD-ENG-4 is revoked?

[Bob Murphie]

Creampuff;

I don't know where your question is leading because I figure (rightly or wrongly), that you are a closet "good guy" despite our being on the opposite sides of the fence at one time or another.

Murphie's Law is absolute, takes precedence over anything CASA office of Legal Counsel can come up with. I know I wrote the book and the amendments from personal experience.

Let me ask you this question;

What will happen if AD/ENG/4 is not revoked.

[Creampuff]

AD/ENG/4 Amendment 10 applies to piston-engined aircraft whose COR holders have elected to use Schedule 5. It says, against the 'Requirement' heading and 'For aircraft in Private operations and / or Aerial Work operations' subheading:To ensure the continuing airworthiness of the engine, and those components necessary for the operation of the engine, in addition to the requirements of Schedule 5 of the Civil Aviation Regulations; carry out the maintenance actions detailed in Appendix A of this Airworthiness Directive (AD).[bolding added]

That suggests AD/ENG/4 imposes requirements in addition to those in Schedule 5. It would seem to follow that if AD/ENG/4 were to be revoked, those additional requirements would cease to apply.

Perhaps people are concerned that if the additional requirements were to be revoked, they would be replaced by something more onerous. I have no insight into whether that would happen or, if so, what the requirements would be.

[Trash Hauler]

The way I see the situation is that CAR 41 requires that the maintenance schedule includes the provisions of maintenance for components. In the case of the engine this information is not contained in Schedule 5 therefore I am still required (as a LAME) to refer to manufactures data for the what, when, how for the engine and its sub-components.

As an AD can overrule the manufacturers data AD-ENG-4 provides alternate requirments that appear to me to be less onerous than the manufacturers data for an aircraft owner. A repeal of AD-ENG-4 would appear to lead to more onerous requirements.

But then again as a LAME at least I can sleep a bit better at night...........:cool:

[ForkTailedDrKiller]

A repeal of AD-ENG-4 would appear to lead to more onerous requirements.


That is my understanding!

The FTDK is due a 100 hrly - I expect it to be lenghty and expensive.

Dr :8

[Creampuff]

[Shakes head in continuing disbelief at the chronic incapacity of Australia to sort this sh*t out]

All, there’s a difference between:

when maintenance has to be done (e.g. annually)

what maintenance has to be done (e.g. replace spark plugs), and

how maintenance has to be done (e.g. using the toys Leaddy says he has, in accordance with the data Leaddy says he has).

The repeal of AD/ENG/4 cannot, in itself, have an effect on all 3, because AD/ENG/4 does not, in its terms, purport to codify all 3.

[Trash Hauler]

I think you lost me Creamy :confused:

[T28D]

We seem to have lost the fundamental fact that nothing is wrong with AD eng 4/7 IT Works and has done for a long time.

[Bob Murphie]

I'm a bit lost here as well Creampuff. But I'll be guided by your wisdom (to an extent).

Schedule 5 is a CASA aircraft inspection schedule, somewhat argueable it now seems for an aircraft. There is an AWB that purports to hold rank over the CASA schedule for maintenance of an aircraft and that the same persons argue makes the schedule redundant ????

AD/ENG/4 is an aircraft engine condition report that gives an on condition extension to the life of the aircraft engine, not the aircraft one imagines. To make this work, certain things (like oil uptake), need to be monitored over the course of the pre-periodical, (100 hours/ 12 months), and again subject to Private and AWK aircraft only.

AD/ENG/4 is not part of a schedule 5 inspection, but "additional" to it unless strict adherence to "hard time" engine data is applied, in which case most engines (ie over 12 years of age or say 2000 hours), would be subject to. ???

As I said before, if it were left alone and not meddled with, what would be the repercussions? Status quo or is there something sinister we don't know about.

If it were meddled with, what then?

Do we go back to prescriptive "hard time" at great cost to us "bottom feeders" or can CASA make it harder or easier?

I think any repeal of any matter should have in place a better replacement prior. This does not appear to have been thought out.

[Creampuff]

At present, CAR 41 says:(1) The holder of the certificate of registration for a class B aircraft must ensure that all maintenance required to be carried out on the aircraft (including any aircraft components from time to time included in or fitted to the aircraft) by the aircraft's maintenance schedule is carried out when required by that schedule.At present, CAR 42B says(1) Subject to subregulation (2), if:

(a) the holder of the certificate of registration for a class B aircraft that is an aeroplane has elected to use the CASA maintenance schedule for the aircraft's maintenance; and

(b) the election is in force;

the aircraft's maintenance schedule is the CASA maintenance schedule.

(2) If:

(a) a person has elected to use the CASA maintenance schedule for an aircraft's maintenance; and

(b) a turbine engine is included in the aircraft;

all instructions issued by the manufacturer of the engine for the continued airworthiness of the engine are to be taken to form part of the CASA maintenance schedule and the election has effect accordingly.So let's assume that we've got a bugsmasher that doesn't have a turbine engine, and the CofR holder had elected to use the CASA maintenance schedule for the aircraft's maintenance. That means the CofR holder must ensure that all maintenance required to be carried out on the aircraft (including any aircraft components from time to time included in or fitted to the aircraft) by Schedule 5 is carried out when required by Schedule 5, and, because the aircraft does not have a turbine engine, CAR 42B(2) does not deem the instructions issued by engine manufacturer to be part of Schedule 5.

Meanwhile, CAR 42V says:(1)A person carrying out maintenance on an Australian aircraft must ensure that the maintenance is carried out in accordance with the applicable provisions of the aircraft's approved maintenance data.CAR 2A defines 'approved maintenance data' to mean:(1) Subject to subregulation (3), the approved maintenance data for an aircraft, aircraft component or aircraft material consists of the requirements, specifications and instructions that are:

(a) contained in the maintenance data set out in subregulation (2); and

(b) applicable to the maintenance of the aircraft, aircraft component or aircraft material, as the case requires.

(2) 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 in documents or designs approved under regulations 22 or 35 by CASA or by authorised persons as to how maintenance on aircraft, aircraft components or aircraft materials is to be carried out; 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.

(3) CASA may, for the purpose of ensuring the safety of air navigation, declare in writing that an instruction mentioned in paragraph (2) (c) or (d) that CASA thinks is deficient is not included in the approved maintenance data for an aircraft, aircraft component or aircraft material.

(4) CASA may, for the purposes of paragraph (2) (e), approve instructions relating to how maintenance on aircraft, aircraft components or aircraft material is to be carried out.

Can someone explain to me which addition to Schedule 5 requirements effected by AD/ENG/4 would, if removed, result in more, or more frequent, maintenance having to be done under Schedule 5, or otherwise, on a piston engine? For the purposes of the CARs, isn't all that 'approved maintenance data' about [b]how maintenance is to be done, not when it is to be done?

Now, it may be that when AD/ENG/4 was originally made, something was taken out of Schedule 5 - I don't know. It may also be that part of the plan to revoke AD/ENG/4 (if - repeat if there is such a plan - I don't know) includes inserting something back into Schedule 5 or issuing a superseding AD - I don't know.

However, I don't understand how revoking an AD that, in its terms, imposes requirements in addition to Schedule 5 can, in or of itself, have the effect of either:

(1) adding requirements on top of those in Schedule 5, or

(2) creating or rejuvenating obligations under the CARs to doing something when specified by the engine manufacturer.

Serious questions Trash Hauler, as you're obviously having to deal with this stuff day-to-day:

(1) How do you 'join the dots' between the CAR 41 and an engine manufacturer's 'when' requirements, given that 'approved maintenance data' are, by definition, 'how' requirements, not 'when' requirements?

(2) Even if you can 'join the dots', how does the existence of AD/ENG/4 sever, entirely, the link to the engine manufacturer's 'when' requirements?

[Bob Murphie]

Thanks for wasting a heap of my time and others who come to the same conclusion that your post as definitive of "our" regulator, is the problem, not the solution to the dwindling GA scene.

Schedule 5 is in fact the manufacturers schedule whatever that may be?

Engines, except for the prescribed maintenance, in the schedule 5 do not confer any ability to extend the life above manufacturers recommendations of public liability except if you interpret the AWB as a biblical stone tablet that again makes schedule 5 redundant?

May I (in jest) suggest we go back to "major inspections" every 4 years and rip off all that Irish linen and replace at 4 yearly intervals with the same stuff and repeal the option of replacing it with Ceconite or Stitts.

[Chimbu chuckles]

At last a sensible post...certainly there are critical items like control lines, throttle cables etc that need to be changed out at regular intervals.

ENG 4 on the other hand is sensible because there is no evidence to suggest that time expired engines signed out under ENG 4 are any more likely to fail than any other engine. (Or is there?)

Not only is there NO evidence that engines operated sensibly and carefully, ie with good monitoring-both direct and periodic, beyond TBO are more prone to failure than those overhauled/replaced at TBO but there is plenty of evidence that engines just overhauled or new are more likely to fail.

The first 300 odd hours on a new/overhauled engine are significantly more risky from an engine failure point of view than the next 2000 hours.

[bushy]

In 15,000 hours of flying the only engine failure due to mechanical failure I saw in an aeroplane I used to fly, happened to a new PA32 that had flown the pacific on it's delivery flight. It suffered a broken camshaft at 200 hours.
I did have two turbocharger failures which rendered the engine useless, but the engine was intact, and worked fine when the turbo was replaced.

[T28D]

Yup nothing wrong with AD eng 4/7 leave well enough alone, if it ain't broke , don't fix it !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! !!!!!!!!!!!

[Creampuff]

Bob: I've read your most recent post four times, slept on it, read it again, stone cold sober, drunk, then hung over, and I am still b*ggered if I know what you meant!

Everyone, I must be missing something that is obvious to others.
Schedule 5 says this, under the heading 'Section 2 The Engine':
(1) Check the external and internal required placards.
Note Reference should be made to the aircraft flight manual and airworthiness directives for the required placards.
(2) Take the following action in relation to the cowls:
(a) remove, clean and inspect the cowls, cowl flaps and fastenings.
(3) Inspect, and record the compression of, each cylinder.
(4) Take the following action in relation to the engine oil system:
(a) drain the sump or tank and refit the plug and lockwire;
(b) drain the oil cooler and refit and secure the hose;
(c) either:
(i) remove, inspect, clean and refit the pressure filter and lockwire; or
(ii) remove, open and inspect the cartridge full flow filter and fit a new cartridge and lockwire;
(d) inspect the oil cooler, oil temperature control valves, oil tank and attachment fittings;
(e) inspect all oil lines, fittings, breather pipe and the oil cooler shutter;
(f) refill the sump or tank with the recommended grade and quantity of oil.
(5) Take the following action in relation to the ignition system:
(a) remove the spark plugs, clean and inspect them, check the spark plug electrode gap, test the spark plugs and renew them if required;
(b) inspect the spark plug high tension leads and ceramics;
(c) inspect the magneto housing;
(d) inspect the breaker compartment and cam follower;
(e) inspect the breaker points for serviceability and check the breaker points gap, magneto engine timing and synchronisation;
(f) inspect the switch and earth leads;
(g) refit and torque the spark plugs;
(h) refit the spark plug high tension leads.
(6) Take the following action in relation to the fuel system:
(a) place the fuel selector in the off position;
(b) remove, inspect, clean and refit the fuel strainers and screens and lockwire;
(c) drain and flush the carburettor fuel bowl and refit the plug and lockwire;
(d) inspect the carburettor or fuel injection components;
(e) inspect the throttle and mixture shafts;
(f) inspect all fuel lines and fittings;
(g) move the fuel selector from the off position;
(h) inspect the auxiliary fuel pump for operation;
(j) pressurise and purge the fuel system and inspect it for leaks.
(7) Take the following action in relation to the induction system:
(a) remove the air filters, clean them, inspect them and refit or renew them;
(b) inspect the hot and alternate air systems for the integrity of seals and for serviceability of valves, shafts, bearings, magnets and hinges;
(c) inspect the induction manifold and hoses.
(8) Take the following action in relation to the exhaust system:
(a) inspect the exhaust system;
(b) remove the muffler shroud, inspect the muffler and refit the shroud;
(c) inspect the muffler internally for security of baffle cones;
(d) inspect the cabin heat flexible hoses.
(9) Take the following action in relation to the engine cylinders and baffles:
(a) inspect the cylinder assemblies;
(b) inspect the cylinder base to the crankcase area;
(c) inspect the rocker covers;
(d) inspect the push rod housing seals.
(10) Take the following action in relation to the crankcase, accessory housing and firewall:
(a) inspect the engine for evidence of oil leakage;
(b) inspect the accessories and drive belts;
(c) inspect the engine mounts and engine mountbolts;
(d) inspect the engine mount frame;
(e) inspect the firewall, including seals and sealant.
(11) Inspect the following controls for full and free movement in the correct sense:
(a) throttle, mixture and propeller;
(b) alternate air and carburettor heat;
(c) engine bay fuel strainer controls;
(d) oil cooler shutter and cowl flap;
(e) turbocharger.
(12) Take the following action in relation to the propeller:
(a) inspect the propeller for static track;
(b) inspect the propeller hub, spinner and backplate;
(c) inspect the wooden propeller attachment bolts;
(d) inspect the blades;
(e) inspect the counterweights;
(f) lubricate the propeller hub;
(g) service the propeller hub with air.
(13) Take the following action in relation to the turbocharger:
(a) remove the heat shield and inspect the turbocharger housing for cracks and oil leaks from the inlet and outlet ports;
(b) inspect the compressor and turbine wheel;
(c) inspect the rotating assembly bearing for end float;
(d) inspect the turbocharger mount;
(e) inspect the transition assembly, the induction and exhaust components and the clamps;
(f) inspect the upper deck pressure manifold and hoses;
(g) lubricate the waste gate linkages and the butterfly valve;
(h) inspect the flexible oil lines;
(j) inspect the controllers and actuators;
(k) inspect the compressor by-pass door;
(m) refit the heat shield.
(14) Take the following action in relation to the refitting of the cowls:
(a) check that no tooling, rags or other foreign objects remain in the compartment;
(b) inspect the latches and fasteners for correct tension;
(c) inspect the inlet and cooling air ducting;
(d) inspect the landing and taxi light wiring;
(e) inspect the cowl flap linkage and engine drain lines.
(15) Chock the wheels and check the brake operation, then set the park brake, start the engine and take the following action to determine satisfactory performance in accordance with the manuracturer's recommendations:
(a) stabilise the engine temperatures and pressures;
(b) check the idle speed, mixture and the magneto switch operation at low engine revolutions per minute;
(c) check the carburettor heat or alternate air operation;
(d) check the gyro or vacuum pressure indication;
(e) inspect the generator or alternator;
(f) check any unusual engine vibration or noises;
(g) check the engine response to throttle application;
(h) check each magneto and propeller governor for operation;
(j) check the static engine revolutions per minute, manifold pressure and fuel flow;
(k) check the idle cut-off operation.
(16) After taking the action described above, remove the cowls, inspect the engine for oil, fuel or other fluid leaks, then replace the cowls.I say again, AD/ENG/4 Amendment 10 applies to piston-engined aircraft whose COR holders have elected to use Schedule 5. It says, against the 'Requirement' heading and 'For aircraft in Private operations and / or Aerial Work operations' subheading:To ensure the continuing airworthiness of the engine, and those components necessary for the operation of the engine, in addition to the requirements of Schedule 5 of the Civil Aviation Regulations; carry out the maintenance actions detailed in Appendix A of this Airworthiness Directive (AD).
[bolding added]

How would revocation of AD/ENG/4 increase the amount or frequency of engine maintenance required by Schedule 5, when AD/ENG/4, in its terms, imposes requirements in addition to those in Schedule 5?

Does anyone believe that AD/ENG/4 replaces the requirements in Schedule 5, despite what AD/ENG/4 actually says?

[Bob Murphie]

I didn't say AD/ENG/4 replaces the requirements on schedule 5, I am saying the AD is in addition to schedule 5 if you want to keep flying the aircraft with an "on condition" engine.

Schedule 5 in itself does not (and I may have to have a drink myself to get focused here), give any extension to manufacturers "hard time" recommendations, AD/ENG/4 does that. Doesn't it?

What does appendix A say?

[Creampuff]

Appendix A looks to me like a list of requirements, and when to do them. AD/ENG/4 Amdt 10 Piston Engine Condition Check 12/2006

Appendix A

Requirement A1:
Carry out an engine performance run to determine the engine performance in accordance with approved data.
For turbocharged / supercharged engines, the output parameters shall be adjusted in accordance with manufacturer’s data.
Record engine and aircraft details and parameters achieved during the engine run on “Piston Engine Condition Report” (CASA Form 728) or an equivalent form. All completed forms shall be part of the engine maintenance record.
Note A1: Where possible, maximum RPM is to be attained with the aircraft stationary. However, where the aircraft manufacturer details in approved maintenance data that maximum RPM can only be achieved during take-off or climb, or the aircraft type does not permit maximum RPM to be safely obtained whilst the aircraft is stationary, an entry on the aircraft maintenance release by the pilot in command of the maximum RPM during the last flight prior to the periodic engine inspection is acceptable data.
Engine run parameters to be recorded include:
a. Take-off power
Take-off power shall be:
i. For a fixed pitch propeller aircraft - static RPM.
ii. For a constant speed propeller, normally aspirated engine aircraft, take-off power shall be maximum RPM at a manifold pressure, not less than 2” of static manifold pressure.
iii. For a turbocharged/supercharged engine aircraft, take-off power shall be maximum RPM at the manifold pressure detailed in the aircraft flight manual.
b. With the engine at operating temperature
i. Oil pressure at idle and at take-off power.
ii. Oil temperature at idle and at take-off power.
iii. Cylinder head or exhaust gas temperature at take-off power.
iv. Fuel pressure/flow at take-off power.
v. Ambient temperature and location altitude.
Requirement A2:
Carry out a cylinder leak check in accordance with:
a. The procedure(s) published by the engine manufacturer; or
b. In accordance with CASA AAC 6-32, where data from the engine manufacturer is not available.
Record the results of each cylinder leak check and / or inspection in the engine logbook.
Requirement A3:
A3(a) Oil change
Replace the engine oil and engine oil filter. Engine oil and the engine oil filter replacement in the period between the aircraft periodic inspections may be carried out by a pilot, other than a student pilot. CAR 42ZC (4) and Schedule 8 refers.
A3(b) Engine oil filter, oil pressure screen and suction screen inspection
All engine oil and engine oil filter replacements, including those carried out in the period between the aircraft periodic inspections, unless carried out by a pilot, shall include inspecting the engine oil pressure filter, oil pressure screen and, if applicable, the oil suction screen, for evidence of metallic particles, shavings or flakes. Take corrective action, where necessary.
A3(c) Engine oil uplifts
Record all oil uplifts. Review oil uplift records and take corrective actions, where necessary.
Requirement A4:
Review all data recorded per Requirement A1, A2 and A3 of this Appendix in order to assess the engine condition.
Note A2: Engines that fail the condition check per this Appendix even after defect rectifications per the manufacturer’s recommendations are to be overhauled. Only airworthy engines (see definition) are to be placed in service.
Note A3: AWB 85-4 “Aircraft Piston Engine Calendar Time Overhaul” provides guidelines for additional inspections related to the calendar time overhaul.
Compliance:
Requirement A1 - At each aircraft periodic inspection.
Requirement A2 - At the intervals not exceeding 100 hours with a planning tolerance of plus or minus 10 hours.
Requirement A3(a) - At intervals as published by the engine manufacturer with a planning tolerance of plus or minus 10%.
Requirement A3(b) - At each oil change and oil filter replacement, if applicable.
Requirement A3(c) - At each oil uplift.
Requirement A4 - At each aircraft periodic inspection.Given what the AD says, the outcome seems to be that if you have elected to use Schedule 5 as the maintenance schedule for a private aircraft, you must do all of the stuff in Schedule 5, when required by Schedule 5, plus all the stuff in Appendix A to the AD, when required by the AD.

I'm still not getting it, and I'm sure there are LAMEs out there who know this stuff backwards.

If we revoke the AD and those additional requirements in Appendix A go away, how does that result in any more, or more frequent, maintenance having to be done on the engine in a private aircraft? Bushy? Trash Hauler?

[jakessalvage]

Not trying to disagree with any of the views people are putting forward. There's 3 sides to every story depending on where in the aviation spectrum you fit. As a LAME my concern with AD/ENG/4 is not the maintenance requirements but the shift in responsibility to the LAME/CAR 30. Here's my logic and I'll apologize in advance if it offends anyone.
First I think its important to understand that an engine that has not exceeded the manufacturers TBO in hours or calender time is operated condition monitored. If at the first filter inspection we find lots of shiny fragments we don't continue it in operation up to the recommended TBO just because its time in service hasn't been reached.
All manner of circumstances may arise during the life of an engine that would require it to be removed from service for repair and returned to service in accordance with the manufacturers recommendations.
The issue when operating beyond the recommended TBO is the continued airworthiness is not in accordance with the manufacturers instructions. Nor is continued operation beyond the manufacturers TBO approved by the country of origin airworthiness authority except for aircraft and engines operated in that state.
Therefore it would seem to me CASA have attempted to add a valuable tool for aircraft owners to allow for operation of an engine beyond the recommended TBO and still provide some continued airworthiness guidelines not approved anywhere else. In trying to do this noble act I believe they have inadvertently shifted the responsibility for continued airworthiness from the certificate of registration holder to the LAME's employer or CAR 30 certificate holder by some poor wording in relation to Schedule 5 and the AD itself.
Here's the really offensive bit, my opinion is that the CofR holder is the only benefactor in the TBO extension cycle, therefore the CofR holder should simply add to their log book statement how an engine is to be maintained if operation beyond the manufacturers TBO is to occur. The AD/ENG/4 should be revoked and rebranded as either an AWB or AC describing a method acceptable to the director how/when/why/etc an engine may be operated beyond the manufacturers TBO for Private and Aerial Work ops.
I also think a law should be passed to stop the abuse of the term on-condition. A component is either condition monitored or its fit and forget, unfortunately most GA owners believe operation of an engine beyond the manufacturers TBO is fit and forget, claims of if it ain't broke don't fix it are illustrations of this.
Maintenance regimes that have correctly identified and maintained components on-condition do so with a maintenance program that normally always increases in testing requirements as time in service increases and also reduces service limits as time in service increases. CASA Schedule 5 and AD/ENG/4 are not individually or combined a maintenance program.
In addition to my proposal I would also outlaw continued operation beyond the manufacturers TBO when the CofR holder changes. The logic is that a diligent operator who has experience and practices that enhance the life performance of an engine is unique and it should not be right that the next owner be allowed to continue the TBO extension. Again this could form part of an AWB or AC, not a rule or AD, CASA are not field/real world savvy enough to do this in any other way in my opinion.
Lastly, I think the idea of using statistics obtained via the CASA defect reporting system as a basis of whether operation beyond the manufacturers TBO is dangerous or not cannot be relied on. Hands up all the Cof R holders who report all the defects on their aircraft. Until this system records 100% of events at best information obtained can at best be described as ,..........interesting, perhaps my own experience are clouding my judgement of this and other issues.
Jake

[Spotlight]

Very cogent and very convincing Jake. As you say there are three sides to every story.

Its not unknown for CofR holders to take their business over the road under the current understanding of the A.D.

[Creampuff]

Thanks Jake

I am intrigued by your statement that: … it would seem to me CASA have attempted to add a valuable tool for aircraft owners to allow for operation of an engine beyond the recommended TBO and still provide some continued airworthiness guidelines not approved anywhere else.I'm still not getting the link between a manufacturer's recommended TBO - a when requirement - and Schedule 5, which, along with applicable ADs, impose the 'when' requirements for the purposes of aircraft whose CofR holders have elected to use Schedule 5 as the aircraft's maintenance schedule.

Perhaps people believe that irrespective of what Schedule 5 says, failure to comply with the manufacturer's recommended TBO may have liability consequences. That belief may be entirely reasonable.

However, I don't see how AD/ENG/4 negates the risk of liability for non-compliance with the manufacturer's recommended TBO.

AD/ENG/4 does not say: "If you do all of these things in addition to the things in Schedule 5, you don't have to do an overhaul when recommended by the manufacturer and you will have no liability for the consequences of not having done the overhaul."

AD/ENG/4 effectively just says: "Do all these things in addition to the things in Schedule 5."

I'd welcome (sensible) completions to these sentences:

(1) Before AD/ENG/4, I was obliged to do an overhaul when recommended by the manufacturer, because ……..

(2) After AD/ENG/4, I am not obliged to do an overhaul when recommended by the manufacturer, because ………

[Bob Murphie]

Jake Quotes: "The issue when operating beyond the recommended TBO is the continued airworthiness is not in accordance with the manufacturers instructions. Nor is continued operation beyond the manufacturers TBO approved by the country of origin airworthiness authority except for aircraft and engines operated in that state".

Which is what AD/ENG/4 addresses in Australia, no?

"Therefore it would seem to me CASA have attempted to add a valuable tool for aircraft owners to allow for operation of an engine beyond the recommended TBO and still provide some continued airworthiness guidelines not approved anywhere else".

Please forgive my quoting out of sequence. Your recommendations should be noted, but I should add that most aircraft C of R holders/ Owners are not qualified nor taught to interpret aircraft or engine log books, nor qualified to direct maintenance or recommend alterations to manufacturers TBO.

One should leave that to the experts who should be reasonably responsible for the work they sign out.

Sorry creampuff, we crossed posts.

[tnuc]

One Issue I have with engines in Pvt/Airwork remaining in service beyond MFRs recomended times is that there is no method in the system to notify the pilot(s) that the engine is operating "beyond" what the MFR says. Not a big deal for privatly owned one owner driver machines, but for aircraft that are hired or used as trainers There should at least be a requirment to put a placard on the aircraft or a note on the MR staing that the engine is beyond Rec TBO, so that persons "hiring" or training in aircraft who dont have access to the log books are advised and can make their own educated decision if they want to fly the aircraft.
If i went to a school to do some training or was to hire for a trip and was paying "top dollar" to use an aircraft i would expect that all systems would be operational and within mfr's limits, if an engine for instance where beyond tbo then i would either not use the aircraft OR would not expect to pay "top dollar" for the privlage of being the test pilot.

Case in point i was at a training org recently and noted that ALL (not some) of their aircraft had engines beyond TBO,for example a B58 with one engine 250 the other 450 over !
Now if the engines are maintained properly there is no reason to think that they are about to give up, (although i didnt see a chrystal ball on the mechanics desk) but to charge the aircraft ot at the full price others are charging for aircraft all within TBO are is a bit hard...

[T28D]

tnuc, how about reading the M/R where it says airwork only AD eng 4/7

[Creampuff]

T28D: You realise, of course, that Amdt 7 has been revoked?

I'd still welcome (sensible) completions to these sentences:

(1) Before AD/ENG/4, I was obliged to do an overhaul when recommended by the manufacturer, because ……..

(2) After AD/ENG/4, I am not obliged to do an overhaul when recommended by the manufacturer, because ………

[LeadSled]

Folks,

Over the years, DCA/DoA/DoT-ATG/CAA/CASA (not certain whether that is comprehensive and in the right order) have had various ways of expressing Australian unique mandatory life limits for engines. My memory tells me the first lists I saw were in the ANO 100 series.

For (essentially) AOC operators, we also have regulatory provision for engine life extension programs, with such as the TIO-540 running up to 2600 hours, well beyond manufacturer's recommended TBO., regularly and reliably.

Until AD/ENG/4, Am.7, there was no practical provision for private and aerial work engines to do the same thing, despite the "rest of the world".

In the best of Australian aeronautical tradition, there was immediate and very noisy objection to the change, with the usual forecasts of death and destruction raining from the sky, including various insurance company "technical experts" ie ex-LAMEs who objected to anything other than what they grew up with!

Prior to AD/ENG/4, Am.7, I regularly came across some really rough engines, but nobody would spend more than the minimum, because they were "close to overhaul". I am of the opinion that AD/ENG/4, Am. 7 and on has resulted in a significant improvement in the airworthiness of GA engines.

I still come across rough engines, but invariably with an AOC operator who has no life extension program, and is only interested in making "TBO" at the minimum expense. Who can blame them, with CASA making it increasingly difficult to establish or maintain an engine life extension program for "commercial" engines.

I am aware of engines in Australian flying schools running up to 3400 hours between overhauls. In the '60's, in UK "we" ran O/IO-540 over 3000 hours, with a couple of light tops.

If you want to know an FAA Part 135 operator's (roughly equivalent of our charter) engine life limits, you need to look at the individual operator's FAA Operations Specification, it will not necessarily be manufacturer's recommended TBO.

Tootle pip!!

[Bob Murphie]

Creampuff;

(1 Before AD/ENG/4, in AUSTRALIA, I was obliged to do an overhaul when recommended by the manufacturer, because there was no provision to do otherwise.


(2) After AD/ENG/4, and for AWK operations, I am not obliged to do an overhaul when recommended by the manufacturer, because any continued operation beyond the manufacturers TBO, (only approved by the country of origin airworthiness authority), did not apply to AUSTRALIA but thanks to AD/ENG/4 this is now possible.

In light of an earlier post, I can only emphasize that the average pilot / owner /operator is not qualified to interpret log books nor audit them sufficiently to able to supervise a maintenance regime other than that suggested by the LAME and schedule 5 and AD/ENG/4 (and it’s amendments), nor are some even qualified to read and interpret a maintenance release.

[jakessalvage]

Hi again

Like most respondents I would like to see engine operation beyond the manufacturers TBO allowed in some format if its not going to be AD/ENG/4 current amendment.
My customers would all agree to a few more guidelines if they were based on real world experiences. For example an engine say used in mustering ops doing 400+ hrs a year has a much better chance of achieving high time in service than a private owners aircraft near the coast doing 30hrs annually.
I see nothing wrong with establishing guidelines for annual utilization or for the frequency of oil/filter changes and component inspection/testing. There may be other criteria as well.
As previously stated, each operator having discussed the process with their LAME long before the overhaul time comes due should include their system on the log book statement.
How about anyone who's interested, contribute their ideas for a better AD/ENG/4, post them here. Sorry I just don't accept the current wording or implementation of this AD is delivering the correct intent or the correct outcomes.
I've never seen or heard of an engine beyond TBO failing, not one, again I am suspicious of the reporting system not that the event has actually occurred. I have removed from service several engines beyond TBO for excessive metal production, excessive oil leaks (cracked cases), and failure to perform on ground runs. I've also had customers take aircraft elsewhere and continue the engine operation when I've thought they shouldn't. To the best of my knowledge none of these ended in in-flight failures. I guess I don't always get it right but I don't mind when the reasons are sound at the time.
I'm also surprised at the differing opinions on this thread all derived from the same legislation. Surely if you were the regulator you'd want everyone understanding the requirements better. Less money on lawyers and more on educators would be appreciated. I'd also challenge industry groups to do more eduction and less grandstanding.
Jake

[Creampuff]

Lots of words, but not quite the precision I was after.there was an inconsequetial regulation that said arbitary TBO's set by arsecovering and money grabbing manufacturers meant I had to overhaul a perfectly serviceable engine that in all probability was less likey to fail than an brand new engine out of the factoryWhich ‘inconsequential regulation’ was that, clearedtoreenter (regulation number please)? Perhaps it was somewhere in the:ANO 100 seriesAnything specific, Leaddy? Given your encyclopedic recollection of the rules, which one picked up manufacturer’s recommended TBO and made it mandatory in respect of private aircraft engines? (1 Before AD/ENG/4, in AUSTRALIA, I was obliged to do an overhaul when recommended by the manufacturer, because there was no provision to do otherwise.I apologise for appearing thick, and I don’t want to be tedious, but what, precisely was the legal link between the manufacturer’s recommended TBO and ‘when’ legal obligations in Australia, and how does AD/ENG/4 sever that link?

I have a strong, uneasy feeling that the belief that compliance with the manufacturer’s recommended TBO was a regulatory requirement, was folklore (happy to be proved wrong – regulation/ANO/CAO number please), or based on a belief about that most bandied about legal term ‘duty of care’ (oooh eeerrr!). In either case, I have a strong, uneasy feeling that it’s folklore that AD/ENG/4, in or of itself, revoked the regulatory requirement (if there was one), or ousted, entirely, all ‘when’ requirements imposed as a consequence of a common law duty of care and manufacturer’s recommendations.

[LeadSled]

Folks.

Anything specific, Leaddy? Given your encyclopedic recollection of the rules, which one picked up manufacturer’s recommended TBO and made it mandatory in respect of private aircraft engines?

I am actually going to see what I can find in old publications etc. Australia did not necessarily just follow manufacturer's recommendations, but published "Australian" life limits.

One I recall is that RR built 0-200's had a much shorter life than a Continental built engine that was nominally identical, from memory 800h v.1200h.

Others were below manufacturer's TBO, but an almost standard series of "100h extensions" usually took the life up to and beyond the said recommended TBO. At leasts in the GODs, there wasn't a swinging fee to apply for each extension, and a long delay for "permission".

Don't hold your breath, but if and when, I will put the references up here.

Tootle pip!!

[Creampuff]

So far in this thread, I've had at least 3 different versions of what the previous requirements were:

1 - the rules required me to do an overhaul when recommended by the manufacturer

2 - the rules specified when an overhaul had to be done, and that may or may not have been at the same time as recommended by the manufacturer (but extensions were granted as a matter of course - a bit like ANO/CAO 48?)

3 - there was no rule that said I was allowed to go beyond the manufacturer's recommend overhaul time, therefore I had to get the overhaul done when recommended the manufacturer.

I look forward to any primary references that support any one of these versions.

[LeadSled]

Folks,
Having consulted a few memories that are better than mine, I have come up with the following:

(1) In the 50's-early 60'2, DCA did a lot of monitoring of engine life, and actual condition at tear down for overhaul. The results were often a lot higher TBO than the then manufacturer's recommended TBO's.

(2) At that time, the Australian TBOs were published (as far as any of us can remember) in ANO 100 or 101.

(3) For reason's nobody really understands, in the mid/late 60's, the method of publication of the Australian TBO became an AD, and the processes for applying for extensions was elsewhere in the regulations. The engine monitoring and life extension programs were well understood by all, and in no way reminiscent of CAO 48 "standard exemptions".

(4) This applied to all engines, it did not differentiate between private, aerial work and charter/RPT.

(5) As Pilykism started to permeate (by now) CAA, the form of the AD (and regulations elsewhere related to extensions) changed, and became AD/ENG/4 for piston engine.

As a note, this was the time of many helpful changes, including "major" being dropped from "major damage", without any consultation of consideration of the results for industry, and greatly increasing the cost of repairs to minor damage, eliminating the ability to do repairs per. FAA AC 43.13.

Some of you may also remember this is when we (those of us with subscriptions?) all got a second free CAR folder, with a happy little note to say this is where we could put all the greatly increased volume of regulations expected to be issued in the "near future". This about 1992.

(6) In 1995/96, AOPA (Dick Smith, President) started the push to get rid of Australian unique airworthiness standards, and Australian unique AD's, and to allow us the equivalent of US/Canada/UK/NZ/SA --- engines on condition for aerial work and private operations ---- not previously permitted in Australia.

That program was finally successful with AD/ENG/4, Am.7. for engines on condition. The rest of the program to get rid of unique Australia ADs has waxed and waned, but once CASR Part 139 went into place, many Australian ADs have been canceled.

CASR 21-35, going in place in 1998, virtually eliminated unique Australian certification standards, but we still have a swag of AD/GEN/ that were/are redundant.

But, after all, this is Australia, and instead of getting rid of all the redundant little "Australianism's", all the "usual suspects" want to put them in CASR Part 90 --Additional Airworthiness Requirements.

Under the present state of the rules, it would be quite feasible to cancel AD/ENG/4 ----IF, AND ONLY IF ---- a proper education program is put in place to get the message across to LAMEs, AWIs, and insurance companies that "recommended" means recommended, and an alternative is put in place to define life for charter/RPT engines. The latter preferably reinstating the well proved process for engine monitoring and life extension used safely and economically from the '40's through to the Rise of Pilyk.

Tootle pip!!

[Creampuff]

Such meandering imprecision is not quite what I’m after.

I find it utterly amazing that, notwithstanding the apparently expensive and unnecessary consequences of being obliged to perform an overhaul on a private aircraft engine when recommended by the manufacturer, no one can cite the regulation or order that imposed the obligation. All those aircraft owners and LAMEs out there who were struggling under the terrible burden of compliance with recommended overhaul periods for so long, and not one of them can cite the regulation or order that imposed the obligation?

Surely when the struggling CofR holder questioned the cost of and need for an overhaul on their smooth running engine, the LAME pointed to a dog-eared and grease-smeared regulation or Order, made by those terrible, aviation-hating CAA or CASA lawyers.

Surely? And surely such an important rule would be burned in their brains and recalled with ease. Surely?

My money’s still on folklore, but am happy to proved wrong with a regulation or order. My money’s on the propagation of a belief that, irrespective of what the rules did or did not require, the common law duty of care required compliance with manufacturer’s recommendations, and that AD/ENG/4 changed that. The first part may well be correct; good luck with the second!

[T28D]

Creampuff, I'm with you, notwithstanding the oblique nature of the regulations governing manufucurers recommendations, there is absolutely no need to mess about with AD eng 4/7 it works.

And the old sayling "If it ain't broke, don't fix it" is valid in this case.

The discussion re: regulation is academically good but it is just that, an academic exercise.

[Bob Murphie]

Yesterday I phoned a LAME who has done a lot of work for me. He stated that his Hangarkeepers Liability Insurance allows him a 25% over run on manufacturers TBO and zero on engines over 12 years of age.

He believes we only have the current AD to work from and doesn't remember the sequence of events but is of the opinion before AD/ENG/4 (7) engines were overhauled at manufacturers TBO. Extensions were applied for on an individual basis.

An Insurance spokesman said LAME's insurance was done on a case by case basis.