ARC and EASA

[tb10er]

Has anyone had any experience of this?

Our maintenance company have advised us that we will require a "back to birth" audit of all serial numbers, etc. on our aircraft. We also have to ensure that all log books, etc. are available since the aircraft was built.

What are your experiences?

[S-Works]

What are your experiences?

That a good number of maintenance organisations are hiding behind the Part confusion to drop a lot of peoples pants........

[robin]

.. but the Belgrano rolled over first, and are not likely to help the rest of us getting stuffed

[Malcom]

:ugh::ugh::ugh:

[vee-tail-1]

If your maintenance company decides to use a 'big shovel' you can expect a big load of sh**t
Try a company with a smaller shovel. :rolleyes:

ARC ISSUE / RENEWAL CHECKLIST.

Documents to be provided by owner / operator:

- REGISTRATION CERTIFICATE, C of A, ARC,
- FLIGHT MANUAL.
- APPROVED MAINTENANCE PROGRAMME.
- CONSTRUCTORS MAINTENANCE MANUAL.
- AIRFRAME, ENGINE, & PROPELLER, LOGBOOKS & DATA SHEETS.
- ROUTE LOGBOOK.
- STATE OF REPAIR OR MODIFICATION.
- STATE OF MAINTENANCE PROGRAMME CONFORMITY.
- STATE OF ADs
- STATE OF WORK REPORTS [SBs, SLs, replacements, etc]
- WEIGHT & CG REPORT.

Examination of Documents:

- FLYING HOURS OF AIRFRAME, ENGINE, & PROPELLER ARE PROPERLY RECORDED.
- FLIGHT MANUAL IS APPROVED AND CONFORMS TO THE AIRCRAFT CONFIGURATION.
- REQUIREMENTS OF MAINTENANCE PROGRAMME ARE COMPLIED WITH, including life limited components.
- M.P. ERRORS ARE CORRECTED, REPORTED, AND APPROVED.
- ADs ARE COMPLIED WITH AND PROPERLY RECORDED.
- MODS & REPAIRS ARE PROPERLY RECORDED& APPROVED.
- WEIGHT & CG REPORT CONFORMS TO THE AIRCRAFT CONFIGURATION.
- ALL MAINTENANCE WORK CONFORMS TO THE REQUIREMENTS OF PART M.


Aircraft Physical examination:

- Presence of required marks and placards.
- Aircraft configuration conforms with Flight Manual.
- Design of aircraft conforms to EASA type approvals.
- No faults apparent other than those reported and approved.
- There is no inconsistency between the aircraft and documents examined.

[S-Works]

How else do you prove that the serial number of every part fitted matches the log book except by a huge inspection.

You don't have to. The aircraft has a valid CofA, the last engineer to inspect and give it a CofA is certifying to the aircraft has been maintained correctly and that all AD's etc have been complied with. Under Part M they are only required to go back to the last CofA to ensure any work or parts applied is compliant.

Hence the comments here and in other place about the 'interpretation' that some maintenance companies are putting into the rules.

Some I have talked to are interpreting the rules in the correct manner, others are not and some are just using it as an opportunity to drop peoples trousers.

[vee-tail-1]

Present this form to your CAMO. If they refuse find another one. :E

Note to inspecting persons in the Sub Part G & I organisation:

There is no requirement by EASA for a ‘Back to Birth’ inspection of documentation in order to issue an ARC.

It will normally be sufficient to start airworthiness review inspections at the issue or renewal of the last NAA Certificate of Airworthiness.

The relevant date and flying hours for G-A...... are therefore:

............... Date at ............... Hours.
Logbooks & documentation from and including these dates and times are available from the owner/operator. Documentation before these dates and times will not be made available.

The aircraft is presented to you for issue of an ARC on the understanding that you agree with the above conditions.

Signed………………. CAMO official.

[robin]

Who is going to be brave enough to be the first to use that form???

[A and C]

NO WAY!

However an audit of all the time life items is required.

As usual someone says that you "only" have to go back to the last C of A but this won't wash if the last guy made a mistake.

What is happening is the maintenance companys who did half the job for 75% of the true price are being outed and the customers of these companys are screaming like stuck pigs because they are now having to pick up the cost of years of shoddy maintenance.

[S-Works]

As usual someone says that you "only" have to go back to the last C of A but this won't wash if the last guy made a mistake.

I am sorry but that does not wash either. It is the last guys responsibility not the new guys. The words from the CAA are that the engineers go back to the last CofA and nothing more. Routine check on lifed items.

If you believed every engineer they will tell you that they always do a better job than the last guy!!!!

[IO540]

but this won't wash if the last guy made a mistake.I thought that maintenance was done on the basis that the previous engineer was trusted. Otherwise, everything is back to birth, every time. Whe is the line to be drawn?

What is happening is the maintenance companys who did half the job for 75% of the true price are being outed and the customers of these companys are screaming like stuck pigs because they are now having to pick up the cost of years of shoddy maintenance.I suppose a lot depends on whether the last company's invoice states what was done, but it can be shown that it wasn't all done. In that case, the MO is liable.

But what happens in the (many) cases where there was tacit collusion between them and the owner (to keep costs down)? I believe this is common in the flight training business, where the paperwork has to look good but the school doesn't want to pay more than necessary. Tricky.....

The other thing is that the rules can never clearly draw the line at the previous service, because that could be used to circumvent a lot of stuff. If you have done an unauthorised (but obvious) mod, you just make sure you change the MO for the next service and they would not be able to question it ;) I have no idea how this could be resolved formally.

[BackPacker]

Article on this in the latest edition of Flyer magazine. If you're just tuning in into the whole CAMO / EASA Part M issue, it's not a bad place to start.

[Malcom]

The words from the CAA are that the engineers go back to the last CofA and nothing more. Routine check on lifed items.

Please provide your link to the written word, as that is what will back me up in court when I take over from Half A Job Bob.

[Malcom]

Veetail, no need for the form, just a note to ARC signatory saying youve had a butchers at the plane and docs and everything is hunky-dory and just sign the damm ARC please and thank you.
Cant see the problem for all those prison cell walls!

[vee-tail-1]

This is getting silly. It is impossible to go back to birth with some aircraft, the documentation simply isn't there. To cross check every part and every part number would mean dismantling the whole aircraft. But paranioa seems to be gripping some MOs. Is it the case that for example: If a 30 year old spam can crashes into a school/hospital etc, and the cause is found to be something that should have been done 25 years ago. But the people who signed up the ARC are held to be liable? How could they possibly know if no paperwork was available. There has to be a line drawn beyond which no liability can be incurred, and that line is logically the last C of A inspection.

[NutLoose]

vee-tail-1This is getting silly. It is impossible to go back to birth with some aircraft, the documentation simply isn't there. To cross check every part and every part number would mean dismantling the whole aircraft. But paranioa seems to be gripping some MOs. Is it the case that for example: If a 30 year old spam can crashes into a school/hospital etc, and the cause is found to be something that should have been done 25 years ago. But the people who signed up the ARC are held to be liable? How could they possibly know if no paperwork was available. There has to be a line drawn beyond which no liability can be incurred, and that line is logically the last C of A inspection.

Whilst I can sympathise with you, It is not paranioa, it is the harsh facts of EASA and whilst you say how can you be held liable for what was carried out 25 years ago? well as the signatory on the ARC I and others are stating that all the inspections on the Aircraft have been carried out, failing to ensure that leaves us all open to prosecution.

One of the main problems stems from EASA's ( note the CAA have diddly squat say in it these days) intrangisence to the requirements as these have really been written in the same terms of an Airline operation. I and others are appalled by some of the content withing LAMPS, such as the requirememnts to replace seat harnesses on Aircraft such as a Cessna 150 WITH NEW every 10 years regardless of usage, the same belts installed in a Cessna 152 do not have this requirement as the manual has not been editied to include it. I do not wish to see owners have to throw good money after bad and it reflects against you as both a Company and an Individual if you are seen to be spending Customers money on items that look like new, but you have to obey the new regulations no matter how distasteful. Various lifed items may well fall under flying hours and with some items say falling at 1000 hrs or less the only way you can ascertain if these have been complied with it either to do a full search through the books or to strip as you put it the aircraft down or replace them.

BOSE X Under Part M they are only required to go back to the last CofA to ensure any work or parts applied is compliant.

Well that gets blown out of the water in the fact that lifed items will often fall out of what was the 3 yearly inspection, A company may well of happily signed out your CofA last time round perfectly legally

1, Because at that time there was no requirement to replace lifed items under LAMS

2, because items where there was a requirement to replace them were in life at that time and would be until the next Annual or C of A

Now under LAMP you have to research the aircraft back to ensure that both of the above have been complied with and now are within the current requirements, hence the need for the books.

Remember you can have your maintenance company submit their own maintenence programme for your aircraft that may remove some of this, it will then be upto the CAA/ EASA to approve it.

Remember no matter how harsh it may seem this research should be a once only thing, once done unless you change companies, it will then just need amendments as new items are added. You think I like spending 2 days of my life trawling through logbooks? I have better things to do.





So I am afraid it is welcome to EASA world I think you should all take a deep breadth, open that Copy of LAMPS that was sent to you and read the words

The owner/operator is responsible for the aeroplane’s continuing airworthiness in accordance with Part M M.A.201.

Owner/Operator Certification Statement
The undersigned undertakes to ensure that the aeroplane will continue to be maintained in accordance with the Programme, Section 3
Responsibilities and Standards.

3.1 Certifying persons must use their engineering skill and judgement in determining the depth of inspection needed and other matters,
which could affect the airworthiness of the aeroplane.

Airworthiness life limitations shall be those published by the state of design type certificate holder and supplementary type certificate
holders.


Ohh and VEE-TAIL, I wish you luck finding someone to sign your little piece of paper........... Perhaps you need to pop down to B and Q and pick up some nice white gravel to put around your plane, it will make a nice ornament on a gate somewhere, because no one will issue you an ARC for it with those constraints unless they are stupid. The one good thing though is the CAA would prosecute you too :)

[IO540]

I think gents you have to remember that

It is not paranioa, it is the harsh facts of EASA and whilst you say how can you be held liable for what was carried out 25 years ago? well as the signatory on the ARC I and others are stating that all the inspections on the Aircraft have been carried out, failing to ensure that leaves us all open to prosecution.

is not UK law. Any prosecution would be done in the UK and you would have the usual defences of due diligence, etc.

This HAS to be the case (i.e. there has to be a backstop, plus UK law applies anyway regardless of the wording of some EASA reg) otherwise the system would be unworkable.

Any residual liability is addressed with insurance and you pay the premium and forget about it. That's how lawyers dentists etc do it.

[robin]

I think gents you have to remember that

Quote:
It is not paranioa, it is the harsh facts of EASA and whilst you say how can you be held liable for what was carried out 25 years ago? well as the signatory on the ARC I and others are stating that all the inspections on the Aircraft have been carried out, failing to ensure that leaves us all open to prosecution.
is not UK law. Any prosecution would be done in the UK and you would have the usual defences of due diligence, etc.

This HAS to be the case (i.e. there has to be a backstop, plus UK law applies anyway regardless of the wording of some EASA reg) otherwise the system would be unworkable.

Any residual liability is addressed with insurance and you pay the premium and forget about it. That's how lawyers dentists etc do it.

Forgive me, but it is the CAA we are talking about and not EASA.

The CAA chose to implement a semi-complete piece of legislation knowing full well it was (and still is) going to be changed to a lighter touch version.
And it will be the CAA that is the judge and jury.

Yes, we could choose to have our day in court but at costs even greater than those of the CAAs.

I would love one of our representative organisations to undertake a judicial review of the implementation of Part M, but..........:hmm:

[S-Works]

Well that gets blown out of the water in the fact that lifed items will often fall out of what was the 3 yearly inspection, A company may well of happily signed out your CofA last time round perfectly legally

Indeed, but checking the lifed items is not a back to birth inspection. It is a check of the lifed items. On a Cessna there are very few lifed items even under Part M. Everything else should be part of a standard annual, AD checks etc.

[NutLoose]

Bose X please read from the book of words, no where does it say check for the last 3 years or take as read what the other company dealing with the Aircraft during its past life did, it says

M.A.710 Airworthiness review
(a) To satisfy the requirement for an M.A.902 airworthiness review of an aircraft, a full documented review of the
aircraft records shall be carried out by the approved continuing airworthiness management organisation in order to
be satisfied that:
1. airframe, engine and propeller flying hours and associated flight cycles have been properly recorded, and;
2. the flight manual is applicable to the aircraft configuration and reflects the latest revision status, and;
3. all the maintenance due on the aircraft according to the approved maintenance programme has been carried
out, and;
4. all known defects have been corrected or, when applicable, carried forward in a controlled manner, and;
5. all applicable airworthiness directives have been applied and properly registered, and;
6. all modifications and repairs applied to the aircraft have been registered and are approved according to Part-21,
and;
7. all service life limited components installed on the aircraft are properly identified, registered and have not
exceeded their approved service life limit, and;
8. all maintenance has been released in accordance with this Part, and;
9. the current mass and balance statement reflects the configuration of the aircraft and is valid, and;
10. the aircraft complies with the latest revision of its type design approved by the Agency.
(b) The approved continuing airworthiness management organisation's airworthiness review staff shall carry out a
physical survey of the aircraft. For this survey, airworthiness review staff not appropriately qualified to Part-66 shall
be assisted by such qualified personnel.
(c) Through the physical survey of the aircraft, the airworthiness review staff shall ensure that:
1. all required markings and placards are properly installed, and;
2. the aircraft complies with its approved flight manual, and;
3. the aircraft configuration complies with the approved documentation, and;
4. no evident defect can be found that has not been addressed according to M.A.404, and;
5. no inconsistencies can be found between the aircraft and the paragraph (a) documented review of records.

I myself am not a lover of this system, as it is so full of holes and has been left up to the individual companies involved to determine the state of play without sufficent guidance being in place, take a look at some of the Company approvals that have been approved for Aircraft types, some have been issued with Cirrus Piston Engined Singles and Twins below 2730 KG.

Well Cirrus have never and have no plans to build a Piston Twin, so ask me how a Regulatory body can get that so wrong??

Additionally some Companies have been forced to put every single Cessna Model on their approval, whilst others simply put Cessna piston Single and Twins etc.... this is down to a lack of guidance for each Surveyor involved with dealing with the applications.

My personal view is the UK lept into this first instead of adapting the year of grace other Countries did in implementing it, so a year down the line when the rest of Europe is up in arms over it all, there will be further changes to the requirements and hopefully with a dumbing down of some of the requirements.

[vee-tail-1]

<< Nutloose 3.1 Certifying persons must use their engineering skill and judgement in determining the depth of inspection needed and other matters, which could affect the airwortiness of the aeroplane >>

At last I am beginning to see the light or rather LAMP/LAMS !

For as long as I can remember GA aircraft have used GENERIC maintenance schedules in the UK. These by their nature required interpretation by engineers as stated above. Engineers could chose to do as much or as little work as they saw fit, and sometimes not enough maintenance was carried out.

In France and other countries by contrast, TYPE -SPECIFIC maintenance programmes have been used. These say what has to be done and when to do it, no interpretation required, and everything laid out clearly in the ATA 100 format. As a result any technically competent person can achieve full and complete maintenance.

If we want to avoid future liability problems, throw out these useless LAMP/LAMS schedules and get a Type-Specific maintenance programme approved for your aircraft.
The French have long been doing this and GSAC will have the relevant programmes on file, for some aircraft probably only in French, but that is one of the official EU languages and we better get used to using it.

Perhaps the paranoia that I see is due to the culture change required in doing things another way. Generic maintenance belongs to a previous age.

[cessnarepairman]

Guy,Guys,

Get a grip. First it was the Millenium bug, then terrorism, followed by bird flu, the credit crunch & now swine flu.

We are either living in fear of the world shutting down due to computer failure, being blown up, loosing our homes or dying of some virulent desease, oh & if you are a licensed engineer being thrown in jail for not following the new EASA rules to the letter.

If you are a conciencious engineer just carry on doing the job like you always have done, no one is going to die because you did not change the seat belts so you are hardly likely to be hauled up before the courts over it. We all know that the CAA will only prosecute if they have a cast iron case against you.

Can anyone remember the last engineer to be found guilty let alone jailed for negligence?. A few years ago a Licenced engineer was tried for a blatent bodge on a helicopter which directly led to the deaths of several people, he was eventually found guilty of "not keeping adequate records"
& as far as I can remember, walked.

As for back to birth investigations, what a load of rubbish, If a part is on a, lets say, 1000 hour overhaul look back through the logbooks 1000 hours, no record of change, then change it. If its a 10 year life, no record,
replace it. Simple. If everyone else has missed it & you then miss it, then it is probably so far hidden in the maintenance schedule that every subsequent engineer/CAMO is going to miss it as well & as such is probably not that important & will not cause a catastrophy.

RELAX!

[A and C]

If you wanted me to change your UK registered aircraft from LAMP to the manufacturers maintenance schedule I would have to get this approved by the CAA, for this they would charge a large amount of money.

And before any of you say that the manufactures schedule for a European aircraft should be approved already by EASA......... well it is but the CAA won't accept it! We have already had this conversation with the CAA and despite schedule being part of the type certificate They say it is "not approved by them for UK aircraft"

I find this situation ridiculous the CAA is not now much more than a regional office of EASA but they can over rule the manufacturers data, could you ever see the FAA office in Detroit suddenly deciding to over rule the rest of the FAA and publish a different maintenance schedule for a Cessna?

[vee-tail-1]

A and C. If that is the CAAs attitude re LAMP & manufacturers Type-Specific schedules, then the mistakes of the past will continue into the future. It's a bit like using a Morris Minor manual as a guide to servicing a BMW, there are bound to be items that are missed. Worse is the fear of litigation under the UK (& USA) adversarial legal system. With generic schedules subject to interpretation by engineers, anything missed could result in an accusation of negligence. Under the UK legal system if a problem occurs someone is assumed to have screwed up and that person must be found and punished. In contrast to the European consensual system which seeks to find the reason for the problem so that it is not repeated. Using my earlier example if a Cessna crashes because some item of servicing was not done in the past, the French would check the maintenance programme to see if the item is in there. If it is then the last engineer to use that programme is clearly at fault. If the item is not in the programme, then no one is at fault and an AD is issued.
I don't know how the present mess is to be sorted out, but it is crazy for engineers to be in fear of litigation for things that they cannot possibly know about due to past use of generic maintenance schedules.

[IO540]

And it will be the CAA that is the judge and jury.

No, the UK Courts will be, and the past shows that the CAA is generally (not always, sadly) pretty smart in knowing what cases they can win.

I think cessnarepairman has it exactly right.

If a part is on a, lets say, 1000 hour overhaul look back through the logbooks 1000 hours, no record of change, then change it. If its a 10 year life, no record, replace it

is how it must work, and that is how it works today (assuming the engineer is the least bit diligent).

As regards TYPE -SPECIFIC maintenance schedules, I have come across this too. Socata planes have this in their maintenance manuals, apparently. The American ones don't but I don't know how one deals with that.

[jxk]

Just out of interest my aircraft has a maintenance schedule included in the POH it requires a 100hr inspection or annual check (same as a 100hr). In my case this would mean only 1 inspection per year as I rarely do more than 100 hrs a year. Can a part G organisation approve this schedule without CAA involvement? The CAA used to charge a fee for approving specific maintenance schedules.

[cessnarepairman]

I know a guy who will draw up a maintenance program for your aircraft based on the manufacturers schedule. He will print off 3 copies, one for you, one for the CAA which he will send to them for approval & keep one for himself.

One of my customers had one drawn up & approved. The cost was about £300 to the author & whatever the CAA cost was. It may not be cost effective in every case but take for example one fairly modern aircraft which we look after. The 50 hour inspection is an oil & filter change, nothing more. If that is what is written in the program then that is all you do, forget about LAMPS.

Another advantage of using a type specific MP is that one can write in all sorts of tasks that can be legally performed by the owner/operator, whether that is a good or bad thing depends on the individual.

The one disadvantage is that you have to follow it to the letter for it to work, e.g. all lifed items & time limited tasks will be written in & must be adhered to. However given the current situation that is what everyone is expected to do anyway.

[jxk]

This rather begs the question, how can the CAA divert from what the manufacturer has ordained as the schedule? How can the CAA override the design authorities programme of maintenance? As I understand it LAMS & LAMP were introduced for aircraft where no maintenance programme existed.
Surely, one should only have to produce the manufacturer's schedule coupled with a list of life items and this shouldn't need any further approval.

[A and C]

I suspect that the CAA refusal to accept EASA approved maintenance Schedules is one of revenue raising and job protection.

[cessnarepairman]

I suppose the key word here is "Approved". Most manufacturers have had schedules in their manuals but they were not "approved" by the CAA.
So the CAA published LAMS/LAMPS which although very generic is approved.

As I previously mentioned there is no problem getting a manufacturers schedule approved, but in my experience in GA most owners will not want to go to this expense.

BTW I have checked with a friend of mine who had a scheduled approved by the CAA & it was FREE!.

[NutLoose]

You all missed what I was saying about searching back, it was in response to the post that you only need to produce a logbook for the last 3 years and that is it. I was trying to show that was not the case.

I heard a while ago that LAMPS may get dropped, it failed in so many ways in my opinion, the main problem was the CAA's desire to be seen as the good guys and keep a version on the go, unfortunately all the baggage that got added made it a pointless exercise, as you cannot simply align the requirements of a 50 50 150 hour regime with a 50 100 50 one, it means you may well end up pulling the thing apart on both the second 50 hr and the 150 hr because the manufacturers manuals require an inspection that you are required to carry out at 100 hrs.

jxk with the hours you do it would not really matter to you as the Annual would fall on the second 50 and would be treated as an annual and not a 50 hr anyway.

A and CI suspect that the CAA refusal to accept EASA approved maintenance Schedules is one of revenue raising and job protection.

Exactly, can anyone tell me why we have Annex 2 aircraft? the only reason they were farmed off in my eyes was for exactly the same reason, it was similar to the MOD situation a few years back where it had to go to the CAA who logged it and then sent it to EASA who actioned it then sent it back to the CAA who logged it as actioned and then returned it back to you........ all that was doing was keeping someone in the loop and hence a job!

[jxk]

Ah but nutloose you miss my point (I think) - that if the manufacturer only specifies 100hr checks then I wouldn't need a 50hr as this seems to be a LAMP requirement.

So only the annual required and that would be the same as a 100hr.

[A and C]

The manufactures may only have a 100 hour check but unless you meet some very tight requirments you will still have to change the engine oil at 50 hours.

[Malcom]

If only it was as black and white as Bose-x wishes!

I've got a lifed wing on my plane. I've found out its not original, I've no idea how many hours its done. I've no idea when it was changed.

Still, thats OK cos I only need to go back 3 years so I wont be liable in any way shape or form as its had a C of A previously:ugh:


Quote:
The words from the CAA are that the engineers go back to the last CofA and nothing more. Routine check on lifed items.

Please provide your link to the written word, as that is what will back me up in court when I take over from Half A Job Bob.

[S-Works]

I've got a lifed wing on my plane. I've found out its not original, I've no idea how many hours its done. I've no idea when it was changed.

So you think that the rest of us should suffer for your poor pre-purchase inspection or your poor ongoing maintenance? But please tell us how this back to birth inspection is going to fix the problem?

[robin]

Broadening the point somewhat, it would be interesting to know:

1) Is the CAA required to review the effects of their implementation of Part M or do they have a get-out clause that says they are only doing EASA's bidding, so it isn't necessary?

2) How many engineers have actually ceased trading as a result of Part M

3) How many owners have walked away from ownership thanks to the increasing cost and effects of Part M (combined with the recession).

Even the major airlines are going through massive reductions in activity and are laying off staff. It is little wonder that we (as owners), paying through the nose out of taxed income, are apoplectic with rage.

This half-*rs*d policy gives us nothing we didn't have before but adds to our financial burdens at exactly the wrong moment.

Certainly, if things go as badly for me as they have for some, my lovely little aircraft will soon either be the victim of a major incident (with me alongside)or she will be gracing the 'For Sale' pages.....:ugh:

[Malcom]

Quote:
I've got a lifed wing on my plane. I've found out its not original, I've no idea how many hours its done. I've no idea when it was changed.
So you think that the rest of us should suffer for your poor pre-purchase inspection or your poor ongoing maintenance? But please tell us how this back to birth inspection is going to fix the problem?

It wont fix it, pretty obviously, the point is if I didnt know before a back to birth review, I would after! T'is hypothetical anyway, anyone not getting a decent pre-purchase check deserves what they get.

But, you still neatly miss the point and avoid the question though!

Quote:
Quote:
The words from the CAA are that the engineers go back to the last CofA and nothing more. Routine check on lifed items.

Please provide your link to the written word, as that is what will back me up in court when I take over from Half A Job Bob.

[jxk]

A & C
jxk
The manufactures may only have a 100 hour check but unless you meet some very tight requirments you will still have to change the engine oil at 50 hours.
Actually 25hr oil change due to not being able to fit a spin-on filter (if this an engine or airframe requirement) but this doesn't mean its a 50hr or 6 month check as per LAMP

[A and C]

This might help with the oil changes........ is it a Robin?

Oil System Parts (http://www.bandc.biz/index.asp?PageAction=VIEWCATS&Category=13)

[vee-tail-1]

jxk
I am also curious about your aircraft, having never come across a certified type with only 100 hour checks.

[NutLoose]

Robin,
2) How many engineers have actually ceased trading as a result of Part M


I know of 4 Licenced on the Airport I work at alone decided to kick it into touch and stop working on Aircraft as they could get more pay without the grief and heartache of having to jump through another set of hurdles and exams simply to carry on what they had been doing for years....... one or two now work on trains!

[jxk]

A & C

Thanks for reply re oil filter adapters but I've tried just about everywhere to find a suitable one; the only one that will fit and is approved is the firewall mounted Air Wolf, but it's still a tight fit and I don't like the way that the connecting pipes fit. And your right about the Robin HRs they have the same problem.

Vee Tail

The 100 hr check is straight out of the POH and is quite comprehensive; perhaps more so than the 100hr LAMP. However, it was what the manufacturer recommended at the time and I'm curious about whether or how simple it would be to move to this rather than following the LAMP because it is type specific.

[Malcom]

How many engineers have actually ceased trading as a result of Part M

Last years single all encompassing Part 145 approval has blossomed into Part 145,Part M(GI), A8-15, and A8-20, each has its own MOE, audit plan and appropriate fee, just so I can to do the same jobs this year.

Library costs just gone through the roof because of Piper & Avantext, constant earache and backtracking or goal post shifting from owners, EASA, and CAA, I reckon a lot will give it up as a bad job imminently.

[robin]

... so will some of us owners, or we'll move to the Permit route. That should give us a few years before Part M comes to the Annexe II fleet.

[Rod1]

“so will some of us owners, or we'll move to the Permit route.”

Just completed my annual permit renewal. Bits, inspection and LAA paperwork came to about £300 all in and the LAA turned the paperwork around in 2 working days.

Is it true that aircraft which qualify for ELA 1 / EASA permit will have a very light touch Part M with extensive user maintenance and the LAA inspectors signing the work off? The first factory built aircraft conforming to the new rules are just arriving, so it will be interesting to see how it all works.

Rod1

[robin]

Rod1

That may well be true, but remember who implements the legislation and their well-earned reputation for gold-plating....:=

[vee-tail-1]

The French are sorting it already!
Under the present French system some competent owners of below 5,7 T aircraft can do most of the maintenance and issue a CRS for their work. They must have an approved & personalised type-specific maintenance programme, and sign a declaration of responsibility for the maintenance of their aircraft. However Part M will severely restrict this arrangement, reducing it to the small number of pilot owner permitted tasks list in Part M annex VIII. So to fix this problem owners are being encouraged by GSAC to apply for a restricted part 66 licence under 'grandfather rights' They will not have to sit any exams, but need to provide a declaration of experience relevant to their aircraft and the work done on it. This results in a part 66 licence in category B1/B2 for less than 5,7 tonne aircraft, and restricted to the owners actual aircraft type. Creative interpretation of EASA rules by the GSAC. Could anyone imagine our CAA being as proactively helpful :hmm: