C172 - PA28 Owners ALERT - GMP is coming!

[jxk]

I would advise as a matter of urgency that owners of these type of aircraft look at the 'consultation' document (below) and voice and write their concerns with regard to proposed Generic Maintenance Programme (GMP to replace LAMP) which is due to close on the 16th March 2012. This is yet another nail in the coffin for people that own these type of aircraft (in my opinion); if ain't broke don't screw it up.
See http://www.caa.co.uk/docs/2263/20120203TemplateGMPforLight%20Aircraft.pdf
and in particular the GMP Guidance.

This document was dated 16/02/2012 consultation close 16/03/2012 and was NOT sent to owners but will undoubted increase the cost of maintenance and ownership.
Initially, it looks as if you will need a 'back to birth' records for your aircraft. How easy is that?
Rumour has it, that EASA wasn't happy with the CAA LAMProgramme and this consultation is as a response to that criticism. I also believe, that at a meeting of engineers and the CAA that they expressed their disagreement with these proposals.
This smacks of BIG & RAF maintenance schedules which do not relate to LIGHT aircraft.

[A and C]

I find myself in total disagreement with JXK on this issue, this despite my inital reaction to this news about nine months back and see the end of LAMP as a chance to get away from a maintenance program that is trying to be all things to all aircraft. This is not BIG maintenance, it should be seen as a chance for you to use an apropriate maintenance program for your aircraft.

Now we will have the chance to use the manufactuers maintenance program, this should be music to the ears of Cessna owners, little more than an oil change at 50 hours and just the 100 hour/annual check to do, most AD's writen for 100 hour repeat inspections and the rest of the items put in the program mostly based on flying hours.

The CAA has not got the manpower to inspect all the changes so it will be rubber stamping what your maintenance providor recomends.

The making or breaking of this rather depends on how well your maintainence providors quality manager knows the regulations, if he has understood the new system than it is likely you will find this an inprovement, if he has not you will end up with a rewriten LAMP with yet more stuff just because he wants to make sure his six is covered.

As I operate two C152's I am looking forward to this I have yet to do the work on the PA 28 program but I dont see it being a different story to the Cessna's.

So often in these pages I read posts asking why things cost so much in Europe and why cant we do things like they do in the USA.........well guys now is your chance to use exactly the maintenance program that the guys in the USA do............the one writen by the maufactures.

[wigglyamp]

Silvaire1

So if you just do an annual inspection and that's it, where is the content laid down for what to do? Surely it's the Chapter 4 & 5 sections of the manufacturer's maintenance manual + any mandated ADs- effectively the approved maintenance programme. This is what is now being proposed for UK aircraft by introduction of GMP.

[A and C]

I am not sure that I like the idea of owners making up the maintenance program as they go along, the problem is maintaning standards.

The UK homebuilt fleet is a case in point, some owners take real pride in their aircraft and on the whole these are better maintaned than any factory built aircraft, however there is a minority that seem to think that flying is about fixing things with sealing wax & string. These aircraft are deathtraps and the LAA is doing its best to put a stop to these low standards.

To most of us who work within the industry the manufactures maintenance program seems to be a good place to start, the advantage of the new system is that you can change things. For instant were the manufacture has mandated flex hose changes based on old technology hoses and you now have teflon hoses fitted the hose life limits can be changed from a six year life time to on condition monitoring.

The bottom line is that if your maintenance company charges you large amounts of money to impliment what should be a cut & paist from the MM plus the AD's & lifed items data that they should already have on file then you are being ripped off.

As said above the CAA will have to rubber stamp most of this because they dont have the staff to cover even a small proprtion of the aircraft in the timescale that EASA have set.

[Pilot DAR]

I have no knowledge of the UK maintenance requirements. However, in Canada, there has been a requirement for the owner/operator of aircraft, both private and commercial, to develop, document and use a maintenance program, for a long time. Obviously those programs for commercial aircraft receive more review from the authority than the private equivilent.

For the convenience of the Canadian private operators, a generic maintenance program is provided by Transport Canada as a starting point. If your aircraft is un-modified, and there is a reasonable inspection checklist and maintenance manual/instructions for continued airworthiness (ICA) document from the manufacturer, you're probably all set.

A very important element of the maintenance checklist is the expectation that supplementary instructions for continued airworthiness required by additional or STC installed equipment or modifications, are also captured. This IS the owner's responsibiliy, and very certainly in the owner's interest. This is where the owner takes responsibility for knowing what is installed on the aircraft, and what the requirements are to keep it airworthy. By creating the maintenance checklist, the owner informs the maintainer as to what is to be accomplished during the inspection, and prevents the maintainer having to do all of the research to assure that everything is captured. If the maintainer thinks that something has been overlooked, it is certain that they will say so, and not sign out the aircraft until it is addressed. If the owner thinks the maintainer is applying un-necessary requirements, the owner may ask the maintainer to show why that task is required.

Additional equipment installed on the aircraft probably came with ICA's It's not up to the maintainer to have a library of all of these, but the owner to provide them as required. Certainly an owner would not expect the maintainer to work on the aircraft without the relevent instructions! Many STC/PMA replacement parts come with ICA's which require different maintenance, than the part which was replaced. This is often a result of "lessons learned" by the STC/PMA holder, who saw the weak points of the original design. I have written such ICA's in the past - they were much more detailed and restrictive than what had existed before.

Many times I have been asked to test fly an aircraft, only to find that something was not installed correctly (or at all), or not set up right. Sometimes I found this in flight :eek:. The maintainer was unaware of the requirement (or evne the mod being on the aircraft), and thus it was overlooked, until I found that it should have been there/done.

An example being a test flight I did on a C 185 floatplane (having recently flown that same plane on wheels). I took off, and it flew somewhat sideways quite nicely. I landed, and asked for a review of the installation of the floats. The plane had no ventral fin - should it? Nope, the installation drawing (once found, after a long search) did not require it. The drawing did, however require the installation of a Cessna spring kit assembly for the rudder, which was completely not installed. Obvioulsy the drawing had not been referenced during the float installation, because the owner had not provided it to the maintainer. The maintainer did not know he had missed something - though he should have...

A good maintenance checklist becomes a one stop shopping list of what is needed, what is not, and an agreed task list between the maintainer and the owner for each inspection. It keeps costs down, and really enables the informed owner to plan and budget for upcoming work, and odd interval requirements. I can't imagine why it is not a good idea!

[peterh337]

It is difficult to draw up hard and fast rules.

For example the mfg maint list for my Socata TB20 is as long as your arm, and contains loads of stuff which is patently unnecessary, like dismantling the emergency gear release valve every 2 or 3 years. There are no apparently lifed parts in that valve (the o-ring seals will last decades) and the job is a real pig, taking a whole day (the LH seat has to come out to be able to climb in there) and IME most mechanics do it wrongly and eventually the threads get chewed up and then you are looking at 4 digits for a whole new valve which is a French made custom machined part. There is also no apparent failure mechanism because the valve contains just one long pin, whose mere sliding movement does the "job" of internally bleeding the pressure, and one can just check that it slides OK every once in a while. As a result, on an N-reg, you don't mess with that valve, and this is not only 100% legal but is also sensible in objective engineering terms.

The underlying issue is that the mfg who compiles the list has an obvious financial interest in making it as long as your arm :)

Also European manufacturers tend be be "European minded" and they tend to throw in everything including the kitchen sink.

I maintain my TB20 on a money no object basis but I don't replace stuff for the fun of it...

But somehow one has to reconcile this with the reality of aircraft maintenance which is that many/most MOs tick all the boxes but only do what they think is worth doing, or what they can be bothered to do in the less honest instances.

What the regulators no doubt see is occassional maintenance lapses and they think that by being ultra prescriptive they can fix that. But they can't. That will never change.

Ultimately one has to accept that GA is less safe than CAT, for various reasons, and most of them are nothing to do with maintenance anyway (which is just as well since CAT is also maintained by humans ;) ).

Regarding ICAs, the FAA is getting quite picky now to make sure every 337d mod has an ICA section. In most cases (avionics) there is nothing to do there, but I am sure an aftermarket turbocharger might have specific instructions :)

[jxk]

Ok, then chaps, let's pretend that I've got the maintenance manual for my aircraft: do you think that I will able to just reference this in the GMP with additional comments about complying with ADs and Lifed items etc. OR will I have to intergrate the whole document into the GMP; nearly 60 pages in my case and as suggested by peter337..
And again who will be responsible for this schedule (and surely schedule rather than programme) the CAA (who A and C says will rubber stamp), the owner or the Part G organisation?
As an aside another aircraft (Cessna) I owned the maintenance manual was an addendum to the POH and was indeed fairly simple but probably not as comprehensive as the current LAMP..

[Mickey Kaye]

A and C please excuse my stupid question.

Does every maintenance provider company have to submit a maintenance schedule for every aircraft that is to be maintained under GMP?

So could one provider submit a schedule for say a Cessna 172 and then every mainentance provider in the country then use the very same maintenace schdule.

[jxk]

So could one provider submit a schedule for say a Cessna 172 and then every mainentance provider in the country then use the very same maintenace schdule. A very good question - and would the CAA compare each submission and reject the least comprehensive.

[Coriolis]

Mickey K,

The only stupid question is the one you thought of but didn't ask.....not stupid at all ;)


"Does every maintenance provider company have to submit a maintenance schedule for every aircraft that is to be maintained under GMP?"

No. Every aircraft maintained under GMP must have a Programme, but it's not the maintenance Co who has to submit or provide it - it's perfectly acceptable for the Owner to submit it. (Although to clarify, if by maintenance provider you mean Engineer or Part 145 Org, it's not their job either - a Part M Organisation has met the standards so would be the place to go if you didn't want to do it yourself.

Or I could do it for the Owner, or you could - it's the Programme which is important, not who does it. But each aircraft has to have a Programme (in that regard it doesn't seem any change to me, as that's what you should already have, either a dedicated MP or an individually-tailored LAMP)

And who owns it (separate unasked question) depends on any agreement between an Owner and anyone else involved.
I know one organisation which has one MP, with multiple reference numbers, reflecting different Owners of almost-identical aircraft, with minor appendices for any differences between aircraft (sounds to me like a good recipe for minimising uneccessary cost) - although I don't know the details of who has ownership of the MP - it may be that the MP is owned by the Company and allows the Owners to 'sign up' to it as one of the terms of the agreement, or maybe each Owner has paid a fee to own a copy in case he wants to move and take it with him - I could see either way working legally....

[peterh337]

The biggest lesson for a new aircraft owner is that a plane is not like a Merc which you can dump at the dealer with the key on the dash and collect it a few days later :)

It's a helluva learning curve, with a pretty severe knowledge v. ££££££££ tradeoff :)

[jxk]

There is no documented maintenance program. Not quite sure what the intention of this comment is, but if you're suggesting there's no maintenance schedule for your aircraft type then this precisely why LAMS and LAMP were introduced.

[A and C]

Each aircraft will have to have its program, this is due to differences in equipment fit, but I expect both my Cessna 152's to have a core program with minor differences to cover the equipment fit. (eg one has a McCaulley prop & the other has a Sensenich both have different maintenance requirements)

Some CAMO's will be approved to approve programs or you can do this via the CAA.

You don't need to copy the aircraft manual into the GMP just make reference to the documents you are using for the GMP.

[jxk]

A and C
Some CAMO's will be approved to approve programs or you can do this via the CAA.And what criteria will be used to approve the CAMO's, existing Part G(i) organisations? And again who will ultimately and legally responsible for GMP; the CAA, CAMO or the Owner?
Presumably, the CAA will charge if they do the approval (£195/hr)? Rubber Stamp!

Don't get me wrong over any of this I'm trying to understand if this a sledge hammer to crack a nut. We're talking about cash strapped owners of average aircraft types not Alan Sugar (who operates on the N reg).

[A and C]

Some CAMO's already have "approval for indirect approval of maintenance programs. These CAMO's already do this and take responsabiltity for the program.

These CAMO's are usually the ones with a full time quality department.

[jxk]

OK one final thing don't you think that owners should have told about this?

I was only made aware of this on a recent visit to my maintenance organisation.

[Coriolis]

With the greatest respect, the question illustrates that at least one poster doesn't routinely follow the information promulgated by the various authorities. How do you think the maintenance organisation found the information to pass to you?

Since an approved CAMO has to demonstrate their systems for doing just that (so they stay up to date with changing requirements), this (amongst other things, like a QA system, qualified and experienced staff, etc etc) gives CAA sufficient confidence that they are competent to manage the maintenance of aircraft in accordance with, etc....

Regrettably, these staff, systems, and general organisation costs money to operate, hence have to be paid for by someone.

Once again, by putting in the time and effort, an Owner can avoid these costs, but if he wants the service he'll have to choose whether to work himself or pay someone to mow his lawn.... or if our friend Silvaire is correct (and I'm sure he knows his rules), an Owner could move to the N-register (but I suspect the end result will be that the Owner will still have to manage his own maintenance, one way or the other) - but perhaps the FAA rules take a different view (they certainly don't seem to crash any more for being somewhat more relaxed.....)

Yer pays yer money and takes yer choice....

[jxk]

With the greatest respect, the question illustrates that at least one poster doesn't routinely follow the information promulgated by the various authorities. How do you think the maintenance organisation found the information to pass to you?I do and because they sent the information to my MO. How do you think I got to know about this in the first place? In the 'good old' days if an amendment to the LAMS was made it was posted to the Owner. Surely with the introduction of such a significant change, it would have been courteous to send them at least a reference to this!
My purpose in starting this forum was to try and make as many people aware of what is happening, as I've found not many people I've discussed this with. know about it.

[A and C]

I did flag this up on these forums in July last year and at the time was of the opinion that it was going to be another disaster, this change looks to be to the advantage of the aircraft owner as long as he produces the new program himself ........... Or has a CAMO that knows what they are doing write the program.

I regularly travel around the industry inspecting aircraft and get to see the badly written company expositions, it would seem that the worst written expositions are usually to be found at the biggest companies.

[jxk]

A and C

I regularly travel around the industry inspecting aircraft and get to see the badly written company expositions, it would seem that the worst written expositions are usually to be found at the biggest companies. And therein lies another story of inconsistencies when approvals are grated for Part 145 and Part M by the CAA.

I know of expositions which were copied, pasted and minimally amended from one organisation to another; one got approval the other not but apparently different surveyors.

[CJ Driver]

jxk asked about promulgation of this change.

I certainly got it sent to my email inbox - surely I am not the only aircraft owner who knows how these things work? The CAA has moved to electronic document distribution of all things - from airspace proposals to maintenance programs to GASIL - some time ago. You register on their web site, select what you want to receive, and they mail them out to you. It's really interesting stuff - and also pretty much vital for anyone who owns and maintains and aircraft.

You DID all know that, didn't you? :confused:

[A and C]

I think you are being a bit unfair on the CAA, if a company exposition is clearly a rip-off of another companies exposition it is unlikely to reflect the nature and scope of the work that is to be carried out.

Given these circumstances it is not surprising the CAA are unlikely to have the wool pulled over their eyes as an inspection of the company facility's will soon show the scope of work that a company is capable of.

[jxk]

I see that I'm not getting anywhere with my thoughts on this subject and hereby lay down and waggle my feet in the air.:ugh::{

[A and C]

I am not sure what your the thrust of your thoughts are, if it is that the change a way from LAMP is expensive then in the long run I don't think that it will be.

If it is that the CAA have not kept the industry informed than that is clearly not the case as I was told about this in July last year, what has changes is that things are not moving at the usual CAA snails pace. This is due to LAMP being found non compliant with EASA regulations and as the CAA is now no more than the UK EASA regional office the bosses expect them to get their act together quickly.

Over the last few years the CAA has gone over to electronic data promulgating and so unlike the good old days when Airwothiness Notices dropped onto the doormat of each licenced engineer if you are not on the electronic system you won't get the data.

I feel that the reason the word did not get on the street is that with the economic squeez hitting the industry so hard most maintenance company's are working so hard that this sort of thing is getting missed, part of this should be seen as a human factors issue as a result of having to work so hard to pay the CAA/EASA fees that are out of step with the economic realitys of general aviation.

[vee-tail-1]

It might help some of us to actually see part of an EASA approved type specific manufacturers maintenance programme. This is for a Robin ATL 'L'

Note: the ATA100 numbering system.
The checks are both calendar (Annual, 3 year, 6 year) and hourly (50H, 100H, 500H, 1000H, 2000H).
There is a column to show Appendix VIII tasks (Pilot/owner permitted)

The top left box is for the owners name which personalises the document in a legal sense.

https://viewer.zoho.com/docs/aV1aW

[wigglyamp]

Interesting maintenance programme for the Robin ATL. I wonder what the response would be if I quoted an inspection to a customer with a PA28 which included the complete removal of the flying control cables for detailed inspection? Perhaps GMP based on a manufacturer's programme isn't best and LAMP +AD & SB is actually OK!

[vee-tail-1]

You mean you DON'T check all the flying control cables at 1000 flying hours!?:eek:

It's actually not too difficult to remove the cables on an ATL so the requirement is a reasonable one.

Every French registered PA 28 is maintained using an EASA type specific programme similar in form to the example shown. But of course it will list tasks as appropriate to the aircraft design & equipment.

As I posted before, these fully updated and approved PA28 EASA maintenance programmes exist now in the French language. It is surely easier & cheaper to translate one into English rather than develop another one from scratch. Or do people enjoy reinventing the wheel? :ugh:

[wigglyamp]

The French maintenance programmes will have been approved by the DGAC acting as it does on behalf of EASA. What view have the DGAC taken in respect of life's-items specified by the manufacturer but not mandated by FAA or EASA? Many posters have made clear their view that such items are just 'recommendations' but our surveyor has made clear that in getting a programme approved, manufacturer-stated component lives and inspection requirements must be respected and cannot be altered without specific justification and the same will apply to SBs.

[peterh337]

Welcome to Europe, Silvaire :)

That Robin schedule looks similar to the TB20 one. Mine is here (http://www.zen74158.zen.co.uk/aviation/tb20-annual-inspection-list.pdf) - taken out of the Feb 2006 MM/IPC CD which is fairly freely available. Actual aircraft production ceased in 2002.

[vee-tail-1]

http://www.regles-osac.com/OSAC/fascicules.nsf

wigglyamp.
I don't have an EASA/OSAC approved PA28 maintenance programme to hand, but it's not all gloom & doom ... for example it is still possible to run Lycosaurus engines beyond manufacturers TBO under OSAC/part M rules.

See: Partie 4, P-41-40 Moteur a pistons, temps de fonctionnement.

Beware CAA surveyors 'gold plating' when reinventing the wheel by 'developing' yet another quite unnecessary maintenance programme.

[wigglyamp]

Peter337

In your Socata programme, one item (37.00 item 5) is replacement of the standby vac pump at 500 hours use or 10 years. Do you consider this a recommendation or a mandatory item?

[peterh337]

I don't have one.

But...

A standby vac pump is just a normal vac pump screwed onto the end of a DC brush motor, and the lot is flogged for a few thousand quid. There is no time-based degradation mechanism in a standard dry pump, or in the motor.

So a visual inspection (assuming one is possible) should suffice.

Replacing at 500hrs flight time is outrageous. That could be 3 years for a "busy" private owner. 10 years... depends on the inspection possibility.

[wigglyamp]

The pump life of 500 hrs is based on it's operating time and on some aircraft it's measured by a Hobbs meter connected to the motor. It doesn't relate to flight hours.

[peterh337]

OK, but who will run that motor for 500hrs?

A standby vac pump unit

http://www.peter2000.co.uk/aviation/tb20-experience/standby-vac.jpg

gets turned on only if the main vac pump fails, which happens almost never. It should never reach 500hrs of running time.

If you want a second vac pump, and running all the time, screw it on the back of the engine (most engines have a spare vac pump mounting point) and save yourself the considerable weight of the electric motor, not to mention the impact on CofG of that weight so far forward.

Otherwise, in a plane which is used routinely for flight in IMC, replacing a vac pump every 500hrs is a reasonable policy. That's what I do, more or less. They cost a few hundred bucks, and cost less if you buy a whole box of them from the USA with an 8130-3 - just like the UK aviation shops who then flog them off with an EASA-1 form tucked in the box :)

But a pilot should not be compelled to do this - the wisdom of it depends on whether he flies significantly in IMC. The vast majority of private pilots don't, and in any case aircraft certification is not controlled by the privileges of the pilot flying it.

I make the decision based on the value I place on its failure, which is significantly affected by the fact that if the pump goes, so does the KI256 horizon, and then the KFC225 autopilot is lost too :) Many/most IFR pilots do not have such a weakness in their systems, and also most don't do the long trips which I do where I really do not want things to pack up.

Incidentally, I carry a spare vac pump, spare filters, and all tools needed to change it, in the boot, all the time :) The ~ 1kg extra weight is very cheap insurance.

You have got good value here out of your two 1-liners, wigglyamp :)