Magneto calendar overhauls - the thin end of the wedge?

[Brainy]

So, my maintenance provider is telling me that is a CASA requirement now that my magnetos (Bendix) are overhauled as per the manufacturer's suggested calendar interval of 4yrs (private category aircraft). Sounds like BS to me - CASA may be leaning on the maintenance providers to comply, but nowhere can I find the relevant AD and it certainly is not specified in the Airworthiness Limitations of the maintenance manual for the aircraft. CAAP 42(B) 1 specifies 'special techniques required by the manufacturer' are to be complied with, but a magneto overhaul doesn't sound like a 'special technique' to me. I can't find anything in schedule 5 (under which the aircraft is maintained). AD ENG 4 private category 'on condition' maintenance relates to the engine and components, of which a magneto is one.

I am happy with a 500 hour inspection period for each of my (4) magnetos, but where has this O/H 'requirement' come from, and where is it going to lead more importantly - the end of on-condition maintence of anything?

I'm inclined to politely decline until someone shows me the magneto AD that I am obviously missing. Am I reading this wrong - what has been the experience of others?

[Eddie Dean]

Service Bulletin 643 details the calendar requirement of four years

[Brainy]

Sure it does, I have read that. It is neither an AD nor an item in the airworthiness limitations section of the aircraft maintenance manual, so compliance under private category of operations is not mandatory by my reading. Am I wrong? (I am fully aware that I may be - hence my reason for posting). My engine has a manufacturer's recommended calendar TBO of 12 years, yet I am not required to overhaul it then, as it has appropriate on-condition monitoring (as do my magnetos at 500 hourly intervals - and every time I fly). How can one be justified yet the other not?

[yr right]

Check your lbs. also what type of aircraft do you have.
Another case of trying to shot the messenger.
Depending on your aircraft you will find it I chapter 5 of your aircraft m/m

[yr right]

Check your lbs. also what type of aircraft do you have.
Another case of trying to shot the messenger.
Depending on your aircraft you will find it I chapter 5 of your aircraft m/m

Just because your are using shedule 5 it dose not discule you from complying with manufacturers sb tbo msb etc. the only disculsion you have from them is if an AD gives you that right or you have it on your LBS.

[Brainy]

can you direct me to where in the regs it decrees that manufacturers' SBs are mandatory? I can't find it. Not trying to shoot the messenger, in fact I would love it if (as the registered operator responsible for the airworthiness of the aircraft) CASA communicated directly with me, rather than telling (should at read threatening?) the maintenance providers what they should be telling me. Puts the shops in a difficult position, I realise. Show me the reg that determines this stance, that is what I need.

[Brainy]

Sure, we're all getting told that, because that is what CASA are telling the maintenance providers. I just can't find where the regulation is that supports the position for private ops. Unless it is mandatory and in the regs I can't see that we need to accept it.

[Brainy]

Wilco. I've almost doubled my post count now in one measly thread. Must be worked up about it. I got burned twice in the past - first with the bonanza elevator cable AD, with which I complied then the AD was amended to inspection only, then in Aug 2013 when CASA introduced the 'everything on published manufacturer's life limits' rule; had my flap motors overhauled, just for CASA to amend their rule a week later. Hence I am not overly keen to waste more money without a clear safety benefit, just 'cos somebody says that CASA says it is a good idea. Show me the AD and I'll gladly comply.

I do have defective colour vision though so maybe it is just written in green and I can't see it. Clearly I am a risk to myself and all around me with my deranged eyesight and magnetos about to self-destruct.

[yr right]

Read the caap in regards to shed 5. In is in that by memory. Also depending on the maintenance org awi the demand that aircraft that have a manufacturer som the lbs must be removed from schedule 5 and places on manufacturers som. This is not just for charter but for private as well.
Casa makes the maintenance org as the police and will prosecute and fine the lame. Lame now are forced to be the bad guys. At the end of the day it's not my or any other lame responsible to take a hit for any owner or operator.
When they ground an aircraft for a missing door decal then you see what we are up against.

[Brainy]

I feel for you guys- I realise that you are basically threatened with litigation (or discipline) from CASA if you don't comply with the latest crusade. However, as the registered operator, it is my election to have the aircraft maintained under the CASA schedule, nobody else's. I'm responsible for the ongoing airworthiness of the aircraft, the shop is responsible for doing the work properly and assessing it as detailed in the schedule. I've read the notes pertaining to sched 5 and it doesn't say I have to comply with the manufacturer's schedules or SBs as best I can see.
From CAAP 42(b) 1: "When the Certificate of Registration holder elects to use the CASA Maintenance Schedule the election includes both the Daily and the Periodic Inspection Schedules".
"6.
Periodic Inspection Schedule
6.1
Limitations Section of the aeroplane’s maintenance manual and any special techniques required by the manufacturer or an Airworthiness Directive are required to be complied with. If it is clear from the terms of the manufacturer’s requirement that the manufacturer considers compliance is optional, then that requirement is optional"

Clearly they are hoping that the 'special techniques' is a catch-all phrase but it is pretty clumsy and definitions could be argued that it does not include standard overhaul of items. This is where I am unsure

[yr right]

Yes but in the mag for instance it dose not make it an option. It's black and white in the sb for magneto for oh periods. There is not an option.
I tried years ago to get Casa to give me a diffusion of the word "recommended "
They would not.
So now even under shed 5 you have to do shed 5.
I had a win in a court against Casa where they said that sb had to be down when using shed 5. I said it didn't. And it didn't at that time. But now you have too. It's that simple. As a lame we damed if we do and damed if we don't.
And at the end of the day yes it is an extra expense on the owner but you the one with your and your families with there arse in the seats.

[Brainy]

Yes but in the mag for instance it dose not make it an option. It's black and white in the sb for magneto for oh periods. There is not an option.
I tried years ago to get Casa to give me a diffusion of the word "recommended "
They would not.
So now even under shed 5 you have to do shed 5.
I had a win in a court against Casa where they said that sb had to be down when using shed 5. I said it didn't. And it didn't at that time. But now you have too. It's that simple. As a lame we damed if we do and damed if we don't.
And at the end of the day yes it is an extra expense on the owner but you the one with your and your families with there arse in the seats.

Yes, I agree. The one and only time I have had an accident though it was as a result of improperly-completed maintenance. So, you will have a hard time convincing me that pulling bits off my aircraft and overhauling them more frequently necessarily makes it safer. I don't skimp on safety or on maintenance. A 500 hour inspection and repair as necessary of the mags would seem to address the issue adequately. I did this last year to my left set of mags. Now I'm being told they have to come off again. Why not take them off and overhaul them every year- surely that will be even more super-duper safe.

Doesn't matter what I think though, it is what the regs say that is important, and I am unconvinced that they say that calendar overhaul of magnetos is mandatory in private category. Maybe I am unusually dense though.

[LeadSled]

Folks,
Put simply, what Australian REGULATION makes Service Bulletins (which are, in the US, not mandatory unless FAA makes them an AD) mandatory in Australia ---- and the question is not limited to private operations.
Tootle pip!!

[yr right]

That may be the case that the magneto manufacturer said repair and replace. But what did the airframe manufacturer say. If it says o/h it is an o/h The airframe manufacturer take prescient over maintence and NOT the component manufacture. Case in point. Pt6a in say a TB700. Is a 100 maintenance schedule. Same engine in a B1900 is 200.

[yr right]

Well no. It is call doing our job. And please explain how it benefits a lame to do this.

Look I call this sort of stuff the "oh **** manov or ". You now ask what's that.
I say when you take off and it goes putt putt rrrrrrr puttttttttt and you go "OH ****".
As for being the police please tell me how we can't be. Are you willing to pay any fines that may be placed on the lame.
At some point you as an owner will now have to make a decision if you wish to play by the rules imposed or sell and hire.
But it gets us all that it's the lame pushing this stuff.
May it's the PM fault as well. As an owner you have acces to Casa. How about next time you have a problem you stop your work shop doing it. Get it written down. Go to Casa with your complaint and get a written exception from Casa. Give it to your lame in writing. He then will not do it. Simples.

[Perspective]

One thing I think that seems to be obviously skimmed over Is the seemingly obvious acceptance of the 500Hr inspection to be carried out, but the same TCM SB643B also states "
C. In addition to the requirements listed above, magnetos must be overhauled or replaced at the expiration of five years since the date of original manufacture or last overhaul, or four years since the date the magneto was placed in service,

We don't have the liberty to pick and Choose.

A good little guide I have linked previously, with references to applicable regs and so on,

http://www.casa.gov.au/wcmswr/_assets/main/lib100178/maint-guide-owner-operators.pdf

"Remember also that under CAR 42V (1), because all maintenance is required to be carried out in accordance
with the applicable approved data, you must still consult the manufacturer’s maintenance manuals for the airframe, engine and propeller,"

CIVIL AVIATION REGULATIONS 1988 - SCHEDULE 5
2.6 In this Part:

" general maintenance inspection " means a regular inspection and check of a class B aircraft, its systems and components that:

(a) is required by the aircraft's maintenance schedule to be carried out at regular intervals.

Many times when having components inspected on calendar time the shop has found defects which left unchecked, at best might leave you stranded away from home, at worst...
But for the most part some owners aren't made intimately aware of all of the things we find on a day to day basis on the component side of things, a cursory look at the flight safety magazine major defect reports section might give you some insight,
Any insinuation that the components are pulled off only because it's of financial benefit to us is complete rubbish and insulting, especially when we pass on the o/haul price at cost and I stlll might wait up to a year to get paid!

"If you do not follow the manufacturer’s maintenance schedule, you should know why, and be able to explain your reasoning to an auditor or accident investigator."

CASA schedule 5 is a list of things to look at.
The manufacturers data tells you how to maintain the aircraft.

and contrary to popular belief we always try to carry out our tasks in the most cost effective way, and it's the hardest thing at times to take commercial pressures out of the decision making process.

I could ramble on, ultimately if I am aware of the Regs directing me to the manufacturers schedule, if I am aware of the SB's, AD's and so on,
For me to then knowingly ignore is negligence.
I am also acutely aware of CASA's intentions, requirements and what they expect of us to keep our CofA, because they make it plainly so in our Audits and whenever we see representatives.

[dhavillandpilot]

When I imported my last aircraft into australia it had mags that had done 225 hours but was out of calendar under the TCM manual.

Naturally I had to have them overhauled so that the aircraft could be placed on the register. At the time I wasn't very happy.

In hindsight my attitude has now changed

So unlike most here who are complaining about their magnetos Which if it wasn't for the calendar requirement would have sat round for years before reaching the magic 500 hours I am happy to comply.

Just remember NO spark NO fly

[Brainy]

When I imported my last aircraft into australia it had mags that had done 225 hours but was out of calendar under the TCM manual.

Naturally I had to have them overhauled so that the aircraft could be placed on the register. At the time I wasn't very happy.

In hindsight my attitude has now changed

So unlike most here who are complaining about their magnetos Which if it wasn't for the calendar requirement would have sat round for years before reaching the magic 500 hours I am happy to comply.

Just remember NO spark NO fly

Doing as you did makes a lot of sense if the aircraft has not been flying much. Would you be equally happy to overhaul every 4 years if you fly100 hours per year?

The issue is 'where is it mandated' that we must comply with an overhaul at 4 yrs as per the SB? The CASA document cited above states 'You are responsible for assessing each service bulletin to determine whether it should be followed or adopted'. They are NOT mandatory. ADs, and airworthiness limitations specified in the service manual are.
Therefore, if the aircraft maintenance manual does not dictate magneto overhaul at 4 yrs, and schedule 5 does not mandate that every SB be complied with, plus there is no AD mandating overhaul at 4 years, it would seem that we can continue to choose to remove, inspect and repair as necessary our magnetos at 500 hourly intervals as an alternative means of ensuring ongoing airworthiness. Am I wrong?

[Perspective]

"The real worry is what next? $600 an hour C182s are not viable."

It has to be put into context,
The old mans house was $20G in 1972, the same house sold recently for over &500G.
The hourly rate for maintenance over the last 20 years has been marginally above stagnant, yet, there are owners buying hangars "tin Sheds" half the size of ours for over half a million bucks, to which our landlord says, well if I can get x for hangerage, then this is your rent! Same to a degree for commercially run aerodromes.
The argument can be made that many other industries, such as my buddies boat shop, where the hourly rate is $110p/H have moved with the times etc.
There has to be a magic number for cost of maintenance, transparent etc, but ultimately, if we continue to barely be able to meet our overheads, then it won't be a decline of GA due to lack of interest, but rather, there won't be anyone left to do the maintenance. Look not only at the average age of LAME's, but the maintenance business owners ages, mostly in their 60's and 70's, who's coming through to replace them.
You can only fit so many workers and aircraft in a hangar and operate efficiently, so even when hours are recorded accurately, transparently, and billed, the margins are exceedingly tight.
That to me is one of the major problems with cost of GA. Yes all businesses have challenges with the cost of doing business, but when we continue to spend the same hours carrying out periodics/100hrly's, and the hourly rate stays the same, then my overheads will start to exceed our revenue. What then.
I could give many examples of industries with hourly rates well above ours, including the fishing boat example, but it is out of context unless you look at the overheads amongst other things.
And so back to Mike Busch and components, we are well aware of applying common sense, human factors and intrusion, right amount of maintenance at right time and so on, but at last check we operate under CASA's Rules and regs, I can't refer my surveyer to Mikes Law!

[Brainy]

Correct, we operate under CASA's rules and regs, but these same regs do not seem to support the advice that it is now mandatory to overhaul magnetos on calendar time. Are you suggesting that the only way LAME shops are going to survive is by doing more unnecessary maintenance? Would you have surgery just because a surgeon said it was a good idea (but not required to keep you alive, safe or additionally healthy) and it maintains the viability of the surgeon's business? I have no problem paying an appropriate market rate for appropriate and properly done maintenance that allows the GA maintenance businesses to remain viable. I do not wish to spend money on maintenance that a)does not provide additional safety and additionally b) is not mandatory that it be done.
When all your GA customers disappear because they have had enough of this BS, how will your business be then? If we all just keep rolling over and taking it, that is exactly what will happen.
So, again, show me where in the regs this is mandated?

[Brainy]

SB643B is not even a 'mandatory' SB. It is marked 'compliance will enhance safety'. So will having your appendix prophylactically removed, along with that of your wife and all of your children, at birth. Doing so will enhance safety. It must. Anyone who thinks otherwise is a danger to themselves.

[Perspective]

"Are you suggesting that the only way LAME shops are going to survive is by doing more unnecessary maintenance?"

Not at all, my point being, there is plenty of scope to carry out maintenance as its required without going over the top, so long as it stays within the bounds
Of the Reg's as they stand. The hours to incorporate the annuals etc haven't changed, but the overheads have increased massively. Hence the hourly rate
Has to change to keep the status quo.

What I do have a problem with, is data that showed historically, for instance vac pumps, on average failing around 600hrs, and having some advocate to not change them until they fail, cause you should be right on the backups etc!

I have a problem with the idea of maintained to failure. I also have a problem with over maintaining and owners being taken for a ride.
Take the proposed Prop AD that might revert to manufacturers periods.
Some say it's over the top, but what climate is the aircraft stored in, how is it used/abused, how much is it used, is it hangared, on a pad, on grass, everyone's experience is different, (SIDS accounts a little for this)component manufacturers have to set a time line to account for all variables obviously, I might think as it lives in wilcannia the calendar shouldn't count due to dry environment, but I still have to abide by the Reg's.
Forgetting the SB for a moment, In my experience, with what is found from time to time in mags for instance inspected on calendar time, it is worth doing.
I would prefer a major inspection style system implemented, but that's for another thread.

[Progressive]

I am going to throw a spanner in the works and say that CASA in fact endorse in their own regulations the on condition operation of engine components where correct condition monitoring has taken place.

It works like this ADs it above all other documents in the CASA hierarchy (therefore an AD overrides contradictory statements from AMM, Engine overhaul and component overhaul manuals.

For private owners AD ENG 4 states:
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).

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.

The above from the AD overrides the manufacturers requirement to do hard life overhaul.

This is also supported by AWB02-1:
Manufacturers Recommended TBO

Aircraft and component manufacturers can make "Hard Time" recommendations (i.e. removal of items from service at a specified period for overhaul or replacement indifferent of the items current performance condition), usually referred to as Time Between Overhaul (TBO), which specify how long they consider their product should remain in service. These recommendations are based on average utilisation and conditions and usually recommend that the item be fully stripped and returned to the original specifications. TBO's do not normally involve a condition check being done during the items life. The ability to escalate these hard time limitations however, comes from effective condition monitoring - the real basis for "on-condition" maintenance.
CASA Recommendations

C of R holders should utilise the philosophy of "on-condition" maintenance to detect the onset of failures of such items, particularly when time in-service of these items are in the vicinity of the manufacturer's recommended TBO.
Provided that a component continues to meet the documented standard, at the appropriate frequencies, it is considered satisfactory to remain in service. TBOs that are not included in the manufacturers Airworthiness Limitations or in Airworthiness Directives issued by CASA should still be considered, unless substantiation has been collated to show the outcome of "on-condition" inspections are still appropriate for the safe operation of the aircraft or equipment.



Where alleviation is permitted beyond the manufacturer's TBO, an example of which would be AD/ENG/4, C of R holders and LAME's must ensure at the completion of the aircraft periodic inspection the "on-condition" maintenance inspection requirements are included on part 1 of the aircrafts maintenance release as "maintenance required".

The hole point of the private section of AD/ENG 4 was to override hard time overhaul limits: See here
www.casa.gov.au/newrules/parts/039/download/ris9802.pdf

[Brainy]

And I agree with everything you just said. I agree that it would be sensible to mandate replacement of a vacuum pump at 600 hours in IFR cat and without a second attitude gyro (not a T&B) powered independently. That would be sensible. Overhauling all 4 of my magnetos every 4 years is not. If one fails in flight, I just get to look at my engine monitor, switch the magneto off and continue to my destination. I have 3 others (which get inspected every 500 hours because it is a good, sensible idea), and a whole spare engine. Where is the risk?

[Perspective]

Brainy.
"SB643B is not even a 'mandatory' SB. It is marked 'compliance will enhance safety'"
So why even do the 500hrly then!? It's the same SB.

It also said,
"magnetos MUST be overhauled or replaced at the expiration of five years since the date of original manufacture or last overhaul, or four years since the date the magneto was placed in service,

Per the Reg's, The components must have an overhaul period, the SB sets out that period. Period.

[Brainy]

Show me the reg that mandates compliance.

[Perspective]

Where's the risk!
Because not everyone's as good a pilot as you, and I can't change the rules to suit you, I have to comply with CASA's view, and when you sell the aircraft to someone else who does have that failure, they won't be as forgiving as you,
Nor the maintainer who then reports me to CASA,
Everyone does this internal risk assessment on the possible outcome of a failure of a component, would it be mad to let go on a single engine, but ok on a twin, would the back up instrument save me, would it cause a fuel leak, how bad, so many variables.
CASA stipulate when using Sched 5, manufacturers Data must be used and that includes components.
The manufacturers data includes all SB's ect. TCM have 5 categories of SB/SL etc. that are referred to.
When the SB states quite clearly, that mags MUST be done at 4 years, I do.
Again, everyone seems happy to do the 500hr, but omit the 4 yearly. It's
The same Doc.

[Brainy]

Exactly. It is not mandatory and 'You are responsible for assessing each service bulletin to determine whether it should be followed or adopted.' in CASA's own words. As to selling the aircraft, it is a piston twin - you can't give them away, so no danger there! 😜

[Perspective]

Ha, agreed.
Cirrus are the new Barron-Cessna 210.

Brainy. The Reg's quite explicitly lay down the manufacturers data is to be followed, along with Component overhaul requirements.

Within the SB referred to, it states in black and white, that Mags MUST....

If the Reg's are the first port of call. To me It goes something like this.
CASA Reg.
Aircraft maintenance Data is to be used for Maintenance.
Components must have a overhaul period.
In the MM, there will be a component overhaul schedule.
If not, you revert to the component manufacturer overhaul schedule.

In black and white, there are overhaul and inspection periods.

The Reg's say you must follow the Data, as its a CASA directive to follow the data, you then must follow the periods set out in the Data, especially when preceded by the word MUST.
This is how our surveyers and Reps state it.
This is also how I see it.

There is copious amounts of waffle and ambiguity within all of the common law pages, CASA Reg's, and advisories, but one thing that shines through is IF you are aware of overhaul periods, and there is not an explicit AD (AD/Eng4/AII) (ADProp/1) to allow an over run, then, as there is nothing saying you don't have to abide by the component periods, they must be adhered to.

[Brainy]

Waffle and Ambiguity indeed. It is near impossible to gain a clear, unambiguous position. Your take on it doesn't make it what is required by law, nor does mine. However, CASA have advised me, as the registered operator of the aircraft responsible for the continued airworthiness of that aircraft, that 'You are responsible for assessing each service bulletin to determine whether it should be followed or adopted'. I am almost as frustrated by this as I am by watching the Lions.

It all just strikes me as CASA getting the maintenance shops to do their dirty work for them. If they believe that magnetos MUST be overhauled every 4 yrs (only bendix ones by the way) because of a risk to airworthiness and safety, an AD should be issued, as compliance is then mandatory. In any case AD ENG 4 applies to 'engine and components necessary for the operation of the engine', so does that not apply to magnetos??

[Perspective]

I believe not.
That's my understanding, that it refers to the engine only.
do me a favor, read tcm sil99-2c.
How it was written in such a way was to appease one
Operator to give flexibility. So I was told by someone
Who used to work at TCM

[Brainy]

I believe not.
That's my understanding, that it refers to the engine only.
do me a favor, read tcm sil99-2c.
How it was written in such a way was to appease one
Operator to give flexibility. So I was told by someone
Who used to work at TCM

That's not fair, you're trying to bore me into submission now!

[Perspective]

Ha, I'll pay that,
Specifically around oil and filter change.
Cheers

[drpixie]

Where's the risk!

It's been long know that maintenance (as well as preventing some problems) causes problems, hence the introduction of on-wear or on-failure maintenance, especially for redundant parts (like magnetos) and delicate parts (like avionics).

I'd be much more concerned about single vacuum failure on a dark and cloudy night, than a magneto problem.

There's only so much money to go around (remember affordable safety) so we should be spending it to get good benefit, not arse covering,

[Eddie Dean]

Drpixie, hopefully you are referring to on condition maintenance which is carried out prior to failure. FWIW Perspective has the right perspective on the magneto overhaul question. Brainy, the OP, just doesn't like the answer.
A way around the issue is for Brainy to have a delegate write up an SOM which excludes magneto overhaul and get it approved.

[yr right]

This $600 fee that is so talked about making out that the lame gets it is soooo wrong it's not funny.
Look at it like this.

Workshop gets prob on average 1 hour worth of work.

So then it's sent to an o/h shop that prob make $100 on it the rest is parts.
Great to see lame,s ripping everyone off.
But I guess it ok to take your Toyota for a service @ $150 an hour and that's ok.

[Eddie Dean]

Well said Yr Right. It takes about an hour to R and R a magneto including adjust internal timing replace points etc. Current hourly pay for a LAME is approx $45, workshop charge out between 120$ and 130$ depending on location. Can't see $600 in there

[Progressive]

Perspective - I'm not sure why you believe magnetos are not covered under the description "components necessary for the operation of the engine" in AD/ENG/4: the magnetos are required for the engines operation, are always included in engine overhaul manuals and supplied by the engine manufacturer.

In addition CASA regularly uses the term "components necessary for the operation of the engine" in other documents referring to engine components including the mags, carbi, turbocharger (where it comes with the engine) but not governor, alternator etc.

Even CASA would be hard pressed to argue that the mag is not required fro engine operation.

[Perspective]

Hi Progressive,
The question was,
"In any case AD ENG 4 applies to 'engine and components necessary for the operation of the engine', so does that not apply to magnetos??""

AD/Eng/4 states, under applicability,
"Piston engines and those components necessary for the operation of the engine, installed in aeroplanes maintained in accordance with Civil Aviation Regulation CAR 42B CASA Maintenance Schedule.",

Requirement A4,
"Note A2: AWB 85-4 “Aircraft Piston Engine Calendar Time Overhaul” provides guidelines for additional inspections related to the calendar time overhaul."

Within AWB 85-4,
"It is recommended that the following procedures are followed for engines that have exceeded the calendar time overhaul recommendations of the engine manufacturers. ALL PROCEDURES listed below, should be performed per approved data where applicable and IN CONJUNCTION with the condition checks per AD/ENG/4."
There are 10 procedures required in addition to those within AD/Eng4.

Procedure 4.5, Check electrical items such as magnetos, spark plugs and harnesses etc for corrosion and malfunction due to moisture ingress and deterioration.

So, AD/Eng/4 tells me carry out performance run on the engine, with additional procedures contained within AWB 85-004, and that all procedures listed, such as step (4.5) should be performed per approved Data IN CONJUNCTION with condition checks etc.

Approved Data relating to the Magnetos would be
TCM SB 643B, and as example S20/S-200 service manual X42002-3 Which notes,
"Magnetos are electro-mechanical devices that use rotating parts and are subject to the same service treatment, environmental conditions and wear as the engine."
Then goes on to state about the 4 yearly inspection etc.

AD/Eng/4 and on to AWB 85-004, including SB 643B specifically talk about environmental conditions being a factor in continued service.

AWB 74-005 also states,
4. Recommendations
Follow manufacturers approved data for maintenance of magnetos. Magnetos operating in harsh environments or operating conditions should be overhauled more frequently than the recommended maintenance intervals....

So, in a nutshell,
AD/Eng/4, note A2 AWB 85-004
AWB 85-004 following procedures to be per approved Data.
4.5 check of electrical items such as magnetos for malfunction, moisture ingress and deterioration.
Approved data is SB643B and x42002-3 S-20 service manual amongst others.
Approved Data states 4 year's etc.

[Brainy]

Which brings us back to the fact that (as per CASA's maintenance guide for owner / operators) "the safety recommendations in an AWB are not mandatory...", so the advice I am being given that I HAVE NO OPTION but to comply with an overhaul of the magnetos on my left engine, which were removed, dismantled, inspected and had parts replaced 130hrs and 1 year ago, is not true. I have not been convinced otherwise.

My issue is solely with the fact that I am advised that CASA has mandated this action, but the fact is that they have not. They may tell the maintenance shops otherwise, but in the absence of an AD requiring action, all of the regs listed above remain advisory in nature.

[Perspective]

I know what your saying, but you can't look at the process of AD's in isolation,
They aren't going to issue an AD for every individual component which are many
And varied, for every different aircraft type and component overhaul requirements therein, you might say, well then just issue an AD stating all components must be done I.a.w. The overhaul schedule,
but the requirements
Already Are that you must carry out maintenance I.a.w. The approved Data,
The MM already gives you the overhaul periods, and under schedule 5 it's stated the components must have an overhaul period.
Again, you can't say I'll do the 500hr, but not the calendar, that's picking and choosing, if the Doc gave you the option of one or the other, that's different.
What gets me, even if you fly maybe 50hrs a year, that's 5g in fuel alone,
20g over 4 years, hangarage might be 20G for the same period, 20G for insurance, (not to mention scheduled servicing) so your paying 60G over 4 years just with those 3 examples, and you can't budget $400 for a 4yr (IRAN) over 4 years for a Mag inspection?

[Brainy]

The money is not the issue. Jeez, flying a pressurised piston twin is a good way to sink buckets of money into GA. It is the principle of enforcement of things that don't arguably provide additional safety over what is currently done (by me in my own individual case), when they are by CASA's own instruments not enforceable. Where is the logical extension of this - no more on-condition running of engines (the majority of the fleet disappears), 6 yr prop overhauls, along with control cables, why not flap motors, Aux pumps, brake callipers, air-con blowers and goodness knows what else. It is regulation for regulation's sake and it is destroying GA. I can afford to overhaul my magnetos, it is not a big item. The question though is why should I, when it is not mandatory and they were stripped and inspected a year ago? Is it safer? Arguably, no. Could that money be spent on something that would have a greater safety benefit, or maybe spend it on actually flying the machine?
Is it raining broken magneto parts and smoking airframes? I think not. Pilots destroy far more aircraft than magnetos do.
I am not picking and choosing - I can elect to ignore the SB altogether, but recognise that a 500hr inspection is probably a wise idea and is cost-effective. I am not convinced that, if I do that, an additional overhaul every 4 years, is. After all, the ongoing airworthiness of the aircraft is the operator's responsibility and, so long as no rules are broken, it seems to me that the operator can legitimately choose to decline the calendar overhaul of their magnetos. Wise? Maybe not, maybe so. Legal? It would seem to be absolutely so.

[Perspective]

"Legal? It would seem to be absolutely so.".

You only really find that out when something happens.

[Brainy]

Unfortunately so. The LAME doing my annual has checked with CASA this morning to clarify our position and confirmed that compliance with calendar overhaul times is not mandatory at this stage. I doubt that will last though.

It is unfair for CASA to make the LAMEs the meat in the sandwich between CASA's 'position' (with complete lack of proper process) and the owners / operators. They (CASA) need to get their act together, legislate appropriately to their wishes and intended outcomes, and then communicate effectively. Not something that any of us are likely to see in our lifetimes I guess. One good thing though I suppose is that they seem to be trying to screw us all over on so many different fronts that it dilutes their effectiveness in doing any of them properly. :}

[Perspective]

I hear ya,
Interesting, not the first time I've heard contradictory information,
Maybe get that in writing, I know I'm going to.
So here we are, I've spoken to my Surveyor and the information is that the SB is created to inform of the
TBO and Inspection periods for the Component.

So I hear you, that because it doesn't say Mandatory Service Bulletin, its optional, Ok then, no probs,
lets look at the Bendix Overhaul Manual, which is part of the approved Data which is consistently referred to on numerous
occasions. As I think most people are now comfortable that the Sched 5 is a list of things to look at, and the Maintenance and Component
overhaul Manual is the Approved Data, what does the approved Data say,
Bendix Manual.
2. "General Overhaul," as specified in Section 7-2, must be performed at the same interval as engine overhaul, or in the event of severe environmental effects
(engine overspeeds, sudden stoppage or other unusual circumstances), or at the expiration of four years without regard
to accumulated engine operating hours since new or last overhaul.

This is from the approved Data, The SB Highlights what's in the Manual.
However you look at it, whether you refer to the SB or Component Manual, the requirements are the same.
Your LAME Would have had it drummed into him no Doubt that he must have the latest revision Data for the Aircraft he is Working on.
Within That are references to the Components and relevant component Manuals.
He may have also read in the Piper manual, where they point out the use of SB's and MSB's, where Piper consider all to be Mandatory!
Some Background info,



from Aviation Occurrence Investigation 200600001, section 1.18.5,
As well as
4.2.2 Airworthiness bulletins and advisories
Safety issue
Currently, Civil Aviation Advisory Publication (CAAP) 42B-1(0) and
Airworthiness Bulletin AWB 02-003 Issue 2, are ambiguous regarding required
inspection intervals for Private category aircraft airframe items. This may result in
the items being operated past the specified aircraft manufacturer’s inspection
interval.
When you look at the Common Law, outlining the application of Schedule 5,

2.6 In this Part:
general maintenance inspection means a regular inspection
and check of a class B aircraft, its systems and components
that:
(a) is required by the aircraft’s maintenance schedule to be
carried out at regular intervals;

The TCM Service bulletin is what's used to outline the TBO Period for the component, in this case a Bendix Mag,
Remember that,
The CASA maintenance schedule, which is Schedule 5 of the CARs, is
widely misunderstood. Many think it replaces and relaxes the manufacturer’s
maintenance schedule.

When using Schedule 5,
6. Periodic Inspection Schedule

6.1 The replacement or overhaul of time-lifed components required in an Airworthiness Limitations Section of the aeroplane’s maintenance manual and any special techniques required by the manufacturer or an Airworthiness
Directive are required to be complied with.

CAR 1988
(f) set out details of the approved maintenance data used to
carry out the maintenance;

I wait to see what I get back from Southern region, But I think I know the answer and am happy to PM you
the results.

[yr right]

Yes totally in odds with what we have to do here. But that's not really to be a suprise. Because no two Casa shops will never give you the same answer. Even when you have them sitting down in front of you they will often be at odds with each other.
One large suprise here I must say is no input from cilnton or Jaba.
Fact of the matter is' if it's in your airframe maintence manual for an o/h period then you have to do it unless you have a your own SOM.
Make sure you have it I writing that's a must

[Jabawocky]

One large suprise here I must say is no input from cilnton or Jaba.

Sorry we have better things to do with our weekends. And that was the comment made on the phone to me by Brainy.:ok: I was at Watts Bridge for a fly in weekend.

So if you really want to know, I have been far from quiet on this thread, you just had no idea. It was last Tuesday, several days before this thread started that I was contacted by SMS and phone about this very magneto matter.

My advice then was that I would not be doing it and ask my LAME to prove beyond doubt that it was required and if in doubt contact CASA for clarification.

Seems my position was backed by CASA.

Oddly enough Clinton and Brainy know each other too. And bugger me if I know where they met last :}

So we have been watching from the sidelines, beer in hand and loving it :ok:

[Perspective]

Thanks Jab, that gave me a chuckle,

An excerpt from a CASA response,

"However, CAR 42V requires persons undertaking maintenance (including inspections) to do so in accordance with applicable maintenance data. CAR 2A(2)(c) defines such data to include instructions issued by manufacturers of aircraft, components and materials."

So,

2A Approved maintenance data
(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 of how maintenance on an aircraft, aircraft component or aircraft material is to be carried out, in documents or designs approved under another provision of these Regulations; 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.

These are the Regs.
Where's the ambiguity.

My surveyers are who I answer to, they direct me to this, they enforce this,
They are my first port of call if doubt exists, if you have correspondence stating otherwise I'd love to see it.

Cheers

[Ethel the Aardvark]

Would it not be simple to ask the C of A holder to just sign a letter instructing the LAME not to carry out sb's sl's. The C of A holder would obviously take full responsibility until such time they become mandatory!

[Perspective]

The only problem with that is the CofA holder probably wouldn't be around
To defend the LAME if the reason you gave him the letter in the first place
Happened!
But I'm sure his family would be understanding..

[yr right]

Sorry even if the CofA holder says no do do it. It is not a legal doco in regards to making the of a MR issue.
But then again what would I know in regards to issuing a MR hey Jaba.
Think you will now find that if you don't wish to do what the required maintenance that has to be done atost work shops you be politer ask that you find another workshop.
Our CofA and lic is worth more than your mags in this case.
I do find your comments Jaba to just say don't do it highly offensive as for someone that not able to actually put his hers lic on the line. But then what else would one expect from your self. Perhaps if you did or could read and understand the legislation your poor attitudei may be different. Easy to say stuff when at the end of the day you don't have any responsibility.

[Brainy]

My day job is (thankfully) much closer to that of a mechanic than a lawyer, but I suspect that 'requirement', 'direction' and 'instruction' are all carefully-chosen words that actually mean quite different things in the regs. None of it is written in a helpful way and it is a galaxy away from plain English.

[gerry111]

Jaba wrote: "Sorry we have better things to do with our weekends."

And that's just so true...

Clinton's lovely V35 was seen parked at Dirranbandi on Saturday night and Moree on Sunday night. It was another successful drought breaking mission for the three of us. So we'll get to the pub at Tilpa, hopefully another time..:)

[Jabawocky]

Sorry even if the CofA holder says no do do it. It is not a legal doco in regards to making the of a MR issue.
But then again what would I know in regards to issuing a MR hey Jaba.

Steve, please respond with your taunts to the person who actually posted the comment. :rolleyes::ugh:

And just for clarity, despite what some folks here THINK they know, it should be noted what the meaning and use of approved maintenance data is and a separate issue of when to do it.

The "approved maintenance data is the "HOW" to do a job, and the maintenance schedule is the "WHEN" to do the job. Don't get them confused folks….:ok:


PS: And by the way, your last crazy and irrational post towards me where I was called a moron (which I do not object to , but clearly the mods did) was a strange attack for which you should apologise and be ashamed of. I was in fact supporting the cause of your family oddly enough. You just went off half cocked about something.

Please play the game with a straight bat hey ;-)

[tnuc]

Has Anyone bothered to look at or ask why TCM requires a 5 year since overhaul / 4 year since installation calendar time overhaul ?

[Perspective]

Maybe not the reason why, but some relevant info for ya, that contains
Defects both mechanical and through interference.

http://www.casa.gov.au/wcmswr/_assets/main/airworth/awb/74/005.pdf

If that doesn't send you to sleep tnuc, interesting article also,

http://www.casa.gov.au/wcmswr/_assets/main/fsa/1998/nov/lame.pdf

[Brainy]

Has Anyone bothered to look at or ask why TCM requires a 5 year since overhaul / 4 year since installation calendar time overhaul ?

No, but I would hope it was after rigorous analysis of a large database of collected SDRs and reported failures, which were analysed statistically and an evidence-based figure of 4 years generated. What I suspect though was someone licked their finger, stuck it in the air and said '4 years seems 'bout right'. Wouldn't it be lovely to be proved wrong, and wouldn't the SB doc make much more interesting and useful reading if the supporting data were presented or summarised?

[tnuc]

The Manufacturers Data from SB643, and the relevant Overhaul manuals differs considerably.

S-1200 Series Magneto’s Manual X42001-2 (Aug 2011)
Section 2.3 – Recommended Maintenance and Overhaul periods

(D) “In addition, it is recommended that magnetos be overhauled at the expiration of four years, without regard to the accumulated operating hours since new or last overhaul.”



S-20 / S-200 Series Magneto’s Manual X42002-3 (Aug 2011)
Section 2.3 – Maintenance and Overhaul Periods

(Last Paragraph) “In addition, magnetos must be overhauled or replaced five years after the date of manufacture or last overhaul or four years after the date placed in service, which ever occurs first, without regard to accumulated operating hours since new or last overhaul.”



D-2000 / D-3000 Series Magneto’s Manual X42003-3 (Apr 2012)
Section 2.3 – Maintenance and Overhaul Periods

(Last Paragraph) “Inspect magnetos and harnesses for airworthiness at the expiration of four years, without regard to the accumulated operating hours since new or last overhaul.”



SB643B Maintenance Intervals for ALL TCM and Bendix Aircraft Magnetos and related Equipment

Sect. 4 Engine Overhaul or Four Year Interval

(D) “In addition to the requirements listed above, magnetos must be overhauled or replaced at the expiration of five years since the date of original manufacture or last overhaul, or four years since the date the magneto was placed in service, whichever occurs first, without regard to accumulated operating hours. Also at this time all related components, including the High Tension Ignition Harness, Starting Vibrator Assembly and Ignition Switch Assembly, must be inspected for airworthiness in accordance with the procedures contained in the latest
revision of their respective Service Support Manual.”

[Perspective]

So if ours is an S-200...

[yr right]

So where dose this end. What about fuel pumps, vac pumps etc etc. the manufacturer places this o/h limits for a reason. Weather you expect that or not that's the case. If you wish to have reliability in your aircraft and don't go on about how someone changed something and now it don't work. Point is the system has changed in regard to maintenance and you all have to except that or get your own som approved and try and convince someone to sign off on it with nil data against what the manufacturer has said. But don't blame the maintenance org for having to enforce something they don't have any option to do and weather or not we have an opinion on it. Because we relize what's good and what's not but we can't change it. And when an AWI grounds an aircraft because one decal is missing on an door well what do you won't me to say.

[Perspective]

Put it this way brainy.
You elect to use the CASA maint schedule 5.
42B1-1.

6.7 Except where otherwise approved or directed by CASA the procedures and limits prepared by the aeroplane manufacturer are to be used when performing an inspection required by this schedule.

42B1-1 does not specifically cover prop, mag, fuel pump periods etc

An example of an AD issued to allow an over run is AD/Prop/1, whereby they
Allow extended periods for Hartzell etc.
If the manufacturers data did not have to be followed in the first place, then why
Would CASA have to issue an AD to allow deviance.
The direction is then, any devience from the data requires direction from CASA.

If you want to deviate from the overhaul limits, this maybe one way, but I'll have to confirm,
As the CofR holder, as you know you are also responsible, if you want to deviate from the limits, you would have to supply me with a written letter, outlining your desire to not conform with the overhaul limits, the approved Data and so on.
Then you would have to guarantee there would be no come back on the maintainer if such component failed, and guarantee no charge of negligence
Bought about by any other party for failing our duty of care.
Then convince a maintainer of such.
otherwise create your own SOM for your aircraft and get it approved by CASA,
But in doing so, you would have to come up with an enormous amount of supporting Data to allow you to deviate from the manufacturers limits.
In this Day and age of litigation, liable, duty of care and so on, how do you think
You would go.
In my experience, with what is found not only at the 500hrly but also at the calendar time, it is worth doing, especially for $4-500 bucks over 4 years.
That's what I would term common sense.

[Aviater]

I beg of people not to base their opinions and/or stereotypes of Licensed Aircraft Maintenance Engineers on yr right.


Most of us are open minded, intelligent and have an excellent grasp of English.


In response to this thread I can add only this; If you trust your LAME and use him/her as your source of advice on airworthiness, then overhaul your components as they suggest. If you believe this to be misinformation and not consistent with the manufacturers data and or Australian regs, then leave them be.


Ultimately it's the certificate of registration holder's responsibility. The LAME can simply ask the CofR holder to sign a letter indicating that he/she has been made aware of the requirements and keep it on file. Everybody goes home happy.


This was done often in regards to the SIDS program when it was first released and people where unsure as to whether is was mandated or not. :ok:

[Brainy]

Don't worry, we don't! I have an excellent working relationship with my LAME, who was also uncertain as to what was mandatory and what was not. I trust him absolutely. It was the advice of a second LAME who had been told by CASA to enforce overhaul of my recently-stripped-and-rebuilt mags, which led to this discussion. Ultimately we checked with CASA and as I have written above, was told that no it was not mandatory at the present time (which, as per my posts above, seems to fit with what CASA's own advice to owners and operators seems to suggest).

Quite how to reconcile this with all the differing opinions, regs and bad punctuation in this thread I do not know, but I know my position. At least for now. I also have $2000 more to spend on flying my aeroplane (which I gather is what it is for) - almost 10 hours' worth of fuel. Safe flying and maintaining, all.

[yr right]

Weather or not I have good English is not a matter for decision really. As for being open minded I'm glad to say I am. I'm willing to put up what I've done in aviation against what you have possibly done.

Next a letter from the CofA holder in case of an accident or incident, death or injury or anything else you can place up will not stand up
The court will see black and white. By meaely giving a letter to have signed by a maintenance org you have admitted that something is wrong. Defense would say my clients did not understand what was given to them. Then what as a lame are you going to say. Please hand me the soap !

[Perspective]

Got my response brainy.
Will PM when time permits, we have to follow the Reg's.
The CMM outlines the periods to follow along with any SB's.
The question whether you give me a letter or not requesting they not
Be done does not change the fact that the reg's require, what they require.
You are still bound to follow the same Reg's as I am, it just becomes a
Blame shift.
In other words, whether you or I take responsibility, it doesn't change the CAR's,
And compliance therein. It doesn't suddenly make it optional because you don't want to do it.
If what your saying is, yours were overhauled 1 year ago, and are due now for calendar, sounds a bit strange anyway.

[baron_beeza]

Weather or not I have good English is not a matter for decision really. As for being open minded I'm glad to say I am. I'm willing to put up what I've done in aviation against what you have possibly done.


Surely this is bluster. I, like many others here, have been in the industry for many decades.
I hold licences for both engineering and Commercial flying from a multitude of countries.
We are talking military, - several countries, Airline, - several countries and then GA. The GA would be many countries, all about the world, including Africa, Asia and the Pacific. Many years in both NZ and Oz as well obviously.

I am unsure what to make of some of these posts. I have put some thought into it and I really can't recall ever meeting any LAME, in any of those countries, with such a poor grasp of the English language.

I honestly can't comment on the content. I am not prepared to make the extra effort to try and read, let alone try and understand it.

A LAME should be able to pay attention to detail, it is a league above spannering or twisting a screwdriver.
Lazy English is either a cunning plan to conceal identity or it is possibly an indication of something else.

I agree with much of Aviater's post.
We are all different and interpretation of the rules could possibly amount to a personal thing. It depends on personality, experience, knowledge, environment etc.
I would expect different guys to have differing views on some of this stuff.

[yr right]

Well baron I am dyslexic. If people don't believe that then let them think that. I too have O/S lic coverage. Worked in five countries had approvals in each or lic coverage. Worked all over Aust in remote locations on my own looking after turbine px aircraft.
What I loose in English skills I make up in other areas.
And if I was so bad I just wondering why I am continually ask what I'm up too. Come work for me. And I work on the principle do it once and do it right. This is what I've done my whole career and coming to nearly 3 decades of being lic I think I must be doing something right.

[LeadSled]

Brainy,
Hang in there!!

The question that everybody (well, almost everybody) is dancing around is, and asked in the first page of this thread, and still not answered is:

" What regulation in Australia makes OEM manufacturer's Service Bulletins (that have NOT been made a country of origine ADs) mandatory in Australia."

This question "goes double" for engines operating "on condition" for private and aerial work operations, AD/Eng/4 refers.

Tootle pip!!

PS: Interestingly, the FSA Nov. 98 article (link in post#61) is legally incorrect in terms of what a LAME is signing for, but if he/she was an FAA A&P operating under FAR 43, the description would be correct.
CASA have prosecuted LAMEs on the difference.

[yr right]

Caap 42B -1(1)

Paragraph 6.1

That states what you have to do if you are useing shed 5.
Now if you can read something different into that I would like to know.


Next country of origin ADs before the change over in by memory in 2009 are not applicable if they are not already set by an Australian AD or added in the future by an Australian Ad or courty of origin Ad.

[yr right]

I've inly heard today that an Australian lame is on man slaughter charges after a fatal accident after a magneto failure. I don't have any other details at this stage. Anyone else heard of this.

[Frank Arouet]

http://i465.photobucket.com/albums/rr13/scud_2008/HowOldMagneto-Billboard-R3.jpg

[LeadSled]

Yr er er er er right or wrong,

CAAP42B-1(1)6.1 does not answer the question of whether/weather/wether (just to give yr a few choices) an OEM SERVICE BULLETIN is mandatory, ie: a maintenance manual instruction, or advisory.

Nobody here has yet come up with a AU REGULATION that makes an SB mandatory.

If you literally take OEM SBs as mandatory, there could be no engines (or most other components) on condition. The bulk of the aviation world (airlines) work their aircraft largely "on condition".

In the airline world (or, if you like, large Class A aircraft) SBs are at the discretion of the registered operator, unless the SB has been made an AD.

Tootle pip!!

PS: With a couple of additions, Schedule 5 is a copy of FAR 43, Appendix D and is (sort of --- see the additions) works the same way -- it is not really a "system of maintenance", it is an inspection schedule for an annual inspection, where applicable the MM for the type is the prime reference for carrying out the work that constitutes an inspection.

[yr right]

And you all wounder why the state of engineers are in such decline.

Leadie just hose to prove you not as smart as you think you are.
Next what is the major difference between an airline and what we are talking about here.
Also components that are on condition have their own tracking and as most large aircraft have multi engines including apu they have a greater redundancy. So when you start to tell us how much you know how about keeping apples with apples and bananas with the bananas what you think.

Also Casa is currently rewriting this whole section to make it more clear to what and what dose not have to be done.

[Aussie Bob]

Also Casa is currently rewriting this whole section to make it more clear to what and what dose not have to be done.

Given their track record this will be never.

[Perspective]

C'mon Leadsled,
". The bulk of the aviation world (airlines) work their aircraft largely "on condition"
That's not entirely the whole story as you know, many airlines have their
Own SOM which usually follows Boeing for instance more of less, and yes have to inspect the health of many components from time to time, even if their not removed from the aircraft,
And there are plenty of components that are life'd also.
(You might term that on condition, with required inspections none the less, you might consider the periodic/100hrly to be the on condition and the IRAN or 4 yearly component change/shop visit).
In other words,
The inference is that components are left if they are working, they are left in use as a result
Of inspections that then allow it to continue in operation.
An example of this may be the allowable time limits for a retract on a Cessna and so on even when the power pack has a major service interval.

(Since it was brought up, if one is going to compare to the airlines, how about we DO adopt some of their maintenance practices, like a major inspection every 3 or 4 years down to the nut and bolt.... Oh hang on a sec, didn't we used to already have something like that!)

The flow of information from maintenance base to engineering, compliance,
Maintenance control is a much shorter route than in GA.
I've seen inspection and change times reduced in response to findings as you would expect.

Most GA operators don't have the avenue of inspecting components in house
To satisfy the major Service Manual requirements, hence why they are sent out.

And that's where the requirements are, remember, you cannot elect to use a maintenance schedule that does not cover the inspection of components that may be necessary from time to time, if you are using a maintenance schedule that does not cover the components fitted to the aircraft, the maintenance schedule is said to be defective and you must notify CASA within 7 days that it is deficient, read that somewhere before?
You can use one of Three maintenance sched's as you know,
But the CAR's explicitly say that forever which one you use, components and required inspections must be covered. Per the manufacturers approved Data.

[rutan around]

Four years seems a short time between magneto removals for inspection regardless of hours in use especially considering each engine has two of them.Surely the chance of both failing on the same flight is very low.

They are pretty robust. When I purchased my pride and joy with a normally aspirated IO 520 engine somehow the magnetos were placed on the life of engine list instead of the component list for periodic maintence. Six years and 1,500 hours later the engine gradually became a bitch to start especially in damp weather. Once it was going it was ops normal. It was sort of self grounding as eventually I guess it would not have started at all. As I was concerned about the starting difficulty I took it to a maintence shop and caused a bit of a flurry when the error was discovered. The overhaul was done, magnetos put on the correct list and I was on my way.

Re the SIDS currently compulsory in Australia it will be interesting in ten years or so to compare our accident rate due to lack of maintence failures with countries such as the US where SIDS is not compulsory.

[Dick Smith]

There will be no measurable difference in the accident rates despite our more expensive requirements .

Otherwise the FAA would have mandated the requirement .

[yr right]

Well let Casa produce a form that legally obsloves a lame from not doing maintenance when the owner operator objects to having it done.
This from MUST also be able to have a civil court not be able to prosecute as well against an maintenance org or lame. Until that happens and havering regs that are at best a disgrace hat had no clear view in other words just shades of grey. As a lame we have no choice. For the pay and conditions and the legal position we hold.
I ask this question.
How many of you would loan you car to someone you don't really know to go away on a trip.
Don't worry they won't speed. And if they do they pay for any speeding fine that you will get in the mail.
Just wondering.

[jeta108]

Magnetos are subject to failure at random. The security of having two will be broken if both are overhauled at four yearly intervals instead of by inspection at regular maintenance. The chances of both having similar problems is now enhanced due to CAsA interference. Well done boys and girls.


The only thing to do is mandate every aircraft has three magnetos and in the case of Chieftans who share electrical outputs from each engine, they shall have four per engine.


This will come to be known as the sure to be sure to be sure to be sure "Australian" magneto regulation. Work is still proceeding at a glacial pace to include an electronic ignition module in each engine worth about $50 in the future.


The holdup is Legal Services Branch who are still working on the paragraph pertaining to who should read the regulation as they are unsure if it is an engineering matter or something pilots should be trusted with and what the final fitted price will be. Airservices have shown interest in this aspect marking a cost benefit analysis project for taxpayer funded installation from savings made from Navaid redundancy.


Affordable safety for all.

[yr right]

I must say after doing a lot of SIDS work and after the fuel contamination after mobile fuel effort.
Being allowed to go in the aircraft in a far deeper way than you can normally access is a real eye opener.
The things we find ln these older aircraft is a real wake up.

[Perspective]

Jeta108. That's why Human Factors is just as relevant in GA as the airlines.
Heard of ETOPS. And they are still inspected at regular maintenance.
I know what your saying, but if you must blame anyone aim it at the
Vendor, it's a bit harsh to blame CASA for saying to follow the manufacturer.
And as time goes on and moves are made to follow the manufacturer closely
By removal of, say, AD/prop/1, no doubt you'll be cursing the regulator then too.

[yr right]

Jeta I really think you need to be damp checked.

[yr right]

By the way. A daul mag has full independent electrical components. It only has a single drive.

[Frank Arouet]

Perspective;


The Battle of Agincourt was the last time such a long bow was drawn. How can you equate ETOPS with 1915 technology?


I think our thesaurus challenged thespian may be due for some intervention by LeadSled after his latest adventure into SIDS, (another acronym), and inward looking metallurgical red herrings. But he is right in telling it as it is with old technology waking him up.

[jeta108]

EFTPOS?
I love aronyms. Haven't had such a challenge since Scurvey.D. Dog was a pup. yrright help me willya, I'm a bit wet.

[Perspective]

Frank, ha,yeah it's a bit of a stretch!
The longest bow in history even Robin Hood would be proud Of!
My point was you quite often have components in both engines
Done at the same time, the risks don't mean you don't do it,
but there are procedures around mitigating
The risks, not generally Employed in GA. Quite a few advocate risk of intrusion as being of greater
Threat.

[Sunfish]

@Perspective; a little knowledge is a dangerous thing.

Large RPT aircraft components are NOT in the majority monitored "on Condition".

"On condition" means components like a light bulb in a toilet. If it fails, change it, there is no measurable effect on safety.

You probably meant: "Condition monitored" where it is possible to measure they safety state of the item, for example a brake pack, which has wear limits or an NGV via a borescope inspection.

If that is not possible we are back to hard time, hours or cycles or maybe by today real time time/temperature history logging.

Stuff expected to be rebuilt are "rotables" which have traceability (e.g. magneto, FCU, etc.)

All else is manufacturers repair scheme.

P.S. If the manufacturer says Four year time in service then that is the applicable limit as far as I'm concerned. Whats got me scratching my head is that I have a brand new engine and prop that are yet to be fitted or run. Should I overhaul them in four years from date of purchase? DAte of manufacture? Date of first run? If not the latter, then Australia will need "use by" dates and we will need to ask manufacturers for the freshest product.

[rutan around]

but if you must blame anyone aim it at the
Vendor, Is the vendor necessarily the best party to determine TBO of components? They have pressures on them that may not produce the optimal outcome for the aircraft owner. Shorter TBOs = more sales = more profit. Also they may be worried about litigation so they chose unaffordable safety.

A cost benefit analysis should be conducted when determining the life of a component coupled with service history and the severity or otherwise of the effect failure would have on the continued safe operation of the aircraft. Also the mode of failure of any part should be taken into consideration. ie Does it give plenty of warning or does it fail suddenly and catastrophically.

Vendors sometimes seem to produce very long lists of components with short TBOs.

In the words of Christine Keeler ' Well they would wouldn't they '

[Perspective]

Sunny,
"The bulk of the aviation world (airlines) work their aircraft largely "on condition"
Is NOT what I said, I was paraphrasing.
I said
"(YOU might term that on condition)
I did say,
"and yes have to inspect the health of many components from time to time, even if their not removed from the aircraft". (I.E, condition monitoring.)

I also said,
"That's not entirely the whole story as you know"
As I usually doodle these on the run I usually don't have time to cover every possibility Or terminology,
But I do like the irony sunny, having owners quote selected doc's,
A little bit of knowledge...
As for your components in storage,
The prop could start from time fitted-run, from memory (hartzell?don't quote me!) AD/Prop/1.
But depending how long you've had it there could be many mods/SB's issued in that time.
Do you have slick or bendix?
I'll have to check slick but bendix, 5years whether used or not,
Or was it a rhetorical question..
P.s.
I enjoy reading your views on a particular airline management philosophy,
Gave me some solace round 08!

[yr right]

Just a matter of fact.

When two components of the same type are changed on a larger type rpt aircraft they are not done by the same people. One team/person dose one side and the other is done by the other/team.
This is not done generally in GA.
Mainly because in GA your not working in a shift and you stay with the aircraft till it's finished.

And by the way there are lots of components that are date time limited.
But I do find it very strange that it's your bums and your families bums in the seats. One would think you would all wish before the best for your aircraft. I'm constantly amazed by owners of their complete lack of self preservation.

[yr right]

So this week I will have to release an engine on a on- condition release.
I will have to do this on my own. I will have nothing from Casa regs to back me up. Nothing from the owner if it goes pear shaped at sometime. I've gone against all sb and o/h periods from all the components manufacturers
So why should I and any other lame take this risk and risk lititagation the possibility of losing my aviation lame lic my house car etc etc.
At what point am I and others allowed to actually place themselves 1st and the owner 2nd.

[Eddie Dean]

Well Yr Right, there in lays the dilemma, and the reason most workshops won't release to service an engine on condition.
The reality though, is that On condition engine overhaul is restricted to Private and Airwork category so isn't a factor for most of the work I am involved in.
BTW Sunfish, on condition does not mean replace when failed.

[yr right]

Yes Eddie that is correct. However most workshops look after all aircraft cats. Very view only look after their own aircraft and don't do outside work and have that ability that know one else looks after their own aircraft.
But this still leaves us between a rock and a hard place In the end

[Frank Arouet]

And a hard place is not a state of mind. It is a real place in history caused by over regulation by the over zealous. I think yr right has identified his problem which we all share. He can't work within the system because the system is unworkable.
The regulatory authorities are the problem, and not the solution.
As someone said earlier, tick tock...

[yr right]

But frank as a lame we can't work without it being Iaw. As such we can only work to a higher standard. This means we do things better than maybe what is required. Then if it dose go pear shaped and the old fella says well what did you do it to you can say what the manufacturer has ask for. If it failed after that I don't have to worry about picking up the soap it's easy to be brave when you don't have to sign for it. As I've said before the hardest word in aviation is NO.

[LeadSled]

Folks,
Just a few comments:

Cessna SIDs are NOT SBs, they are in the manufacturer's MM.

That makes them mandatory for VH- but not N registered aircraft, because FAA maintenance requirements are graded, and found in Parts 91, 121,125,135, not in something called "maintenance" and NOT one size fits all per, CASA.

US piston engine manufacturer's overhaul periods are RECOMMENDED, not mandatory.

None of you has yet come up with an Australian regulation that makes manufacturer's SBs, advisory documents, MANDATORY in Australia, despite me asking the question on several occasions.

Please don't trot out bush lawyer stories, "duty of care" etc., just tell me what Australian regulation make OEM SBs mandatory.

Sunfish,
I do not believe your "light bulb" is a good example of "on condition". With the very greatest of respect, differentiation between "on condition" and "condition monitoring" in this kind of discussion is semantics. As you may or may not be aware, for large turbines, the most important in service monitoring involves fuel flow/performance records, and no two engines have the same gas path rate of wear, with (most of the time) engines being sent for overhaul when the gas path deterioration results in unacceptable increases in fuel flow.

And I am sure you are aware that for components that are "hard time", it is more likely to be cycles than hours.

Tootle pip!!

[Eddie Dean]

A helpful AWI tells me that CAR(1988) CAR 41 para 2 is the regulation that leadsled would need to refer to.

[yr right]

Leadie I beg to differ. For one we are no the USA. Second o/h periods are set by an Australian ad. Next recommend is for time in years only. Next I challenge you to get a diffintion for the word "recommended " from Casa.
In the eyes of the court recommend means you must do. Only option is given by Casa as being an option.
Next your example of what an issue of a M/R is also wrong. It was a civil court that said it was different to what the Car states. In fact Casa told the court what the law was in this regard. But the CIVIL court said that a M/R meant that at issue the aircraft should not break down or have any defects for the issue of the M/R. And just in passing how many have you issued.
Turbine engines are trend monitored. By doing this whilst they many not be completely o/h in their life. Modules are often changed. Your being misleading by your comments. I have change a hyd pump on 747-400 for BA it had an faa release. Had to have special permission to use it. On its return just how luck would have it I changed it to another new pump. This one had a jar release with the next s# from the one I had previously fitted. So don't come and feed bull****e about how large aircraft are on condition because they arnt.

[LeadSled]

CASA CAR 1988 CAR 41
(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.
Penalty: 50 penalty units.
(2) A person must not use a class B aircraft in an operation if there is not a maintenance schedule for the aircraft that includes provision for the maintenance of all aircraft components from time to time included in, or fitted to, the aircraft.


Folks,
See above, that does NOT make a OEM SB on a Class B aircraft component mandatory.

yr er er er, wrong,

I beg to differ. For one we are no the USA.


You can beg all you like, not only did I not say we were the same as the US, I made it very clear that (sadly) we are not.

Second o/h periods are set by an Australian ad.

I assume you are referring to piston engines. That AD is ONLY applicable to engines where "on condition" AD/ENG/4 is NOT applicable, or where engines are NOT on an engine life extension program.

I repeat, the US engine manufacturer's TBOs are ONLY recommended.

Next I challenge you to get a diffintion (sic) for the word "recommended " from Casa.

And what answer to you think I would get --- only an answer with the force of law, because CASA does not have the legal power to declare a "dead parrot" a "resting parrot", much less a "live parrot".

As a definition of "recommended" is not (as far as I can find) in the Civil Aviation Act 1988, the Civil Aviation Regulations 1988 or the Civil Aviation Safety Regulations 1998 Dictionary, the CASA definition will be the Macquarie Dictionary definition. "Recommended" does not mean mandatory or any variation to that meaning. Strangely enough, it means just what it says. Every part of the definition in the Macquarie falls far short (unsurprisingly) of "mandatory".

In the eyes of the court recommend means you must do. Only option is given by Casa as being an option.


If by that incoherent sentence you mean that a Court decision has said that recommended means mandatory, tell us all what the case was, and we can have a look to see if you (or any CASA AWIs) are interpreting it correctly. As for the second sentence, it doesn't make sense, even by your usual standards.

Next your example of what an issue of a M/R is also wrong.

Again, incoherent, what was "wrong". Being wrong in your opinion, and actually being wrong in the legal sense are two very different things.

It was a civil court that said it was different to what the Car states. In fact Casa told the court what the law was in this regard. But the CIVIL court said that a M/R meant that at issue the aircraft should not break down or have any defects for the issue of the M/R.


What are you actually trying to say here, that a Court found that the CASA evidence was not upheld. A Court cannot decided that a statute is "wrong" and substitute something else, but it can certainly find that CASA (or anybody else) has not interpreted the statute correctly.

As to the value of a Court decision as a precedent, that entirely depends in which Court the judgement was delivered, as CASA Legal Services Branch well knows.

And just in passing how many have you issued.


The (apparent) fact that you hold an aviation authorization to produce a form of return to service document does not particularly qualify you as a regulatory expert on the subject, as is continually obvious.

As to my generalized comments about operational life of large turbines, they were correct, if I was to go into detail, it would be quite a large book, and irrelevant to this discussion.

So, you changed a couple of hydraulic pumps, one had an FAA 8130.3, the other had the EASA Form 1 --- BFD, and absolutely nothing to do with the price of eggs, let alone an Australian regulation that decrees that OEM SBs are mandatory for either Class A or B or both, aircraft.

Tootle pip!!

[yr right]

Well at this point of time it is still a maintenance release and not a return of service. The term return to service is directly to stop the court in the above mention.
So how many maintenance releases have you issued. My god your as good as creamie and Jaba in not answering a direct question.
The faa and the jar form was to inform you that eggs are not all ways eggs even when the eggs are the same. Just as you like to confuse the issue.
I also didn't say which reg to look up by the way but I'm guessing your a little confused.

[yr right]

By the leadie.
Please inform us all the difference between a class A and class B maintenance schedule.
Also try now to get an engine extension with out having a program already in place.

The new only extension I know of at this current time which anyone can use is on the PT6. This is AD eng 5. You can purchase a Stc extension program though.

[Sunfish]

Leadie, thank you for your comments, Ive been out of it for a while. Yes there were a number of old LAMES in grey cardigans who condition monitored fuel flow/vibration and performance parameters in my day but they did it on graph paper and almost always generally got it right - changing out an engine or module at just the right time.

As for "on condition" that was where there was a simple Yes/no question regarding replacement and by definition, no safety of flight critical performance item except perhaps windshield wipers and tyres was on that list.

Hard time, not sure what the rules are these days cycles, hours, landings, etc. I would have thought that by now we were doing real time time/temperature/rpm histories for disks.

[yr right]

Leadie can you please also tell us how many aircraft you have places on the Australian regelation and how many log book statements you have done and while we at it how many system of maintenance you have done and had approved.

Thanx

[Perspective]

Evening Leadsled. Oh dear, well, anyway...........back to the topic,
Maybe it's not the answer that doesn't make sense but the question.
Maybe it shouldn't be "What" regulation, but rather who's, bear with me..
Fortunately for me, my AWI's and my correspondence from contacts in CASA
Are consistent. before you State that Yr Rgt is wrong about Car41, if he is being told by his AWI's, CASA contacts and so on, that that 'Includes' SB's, and they are the ones he must comply with, then according to the ones who allow his CofA and Licence, he is right!
At least in the eyes of the ones whom regulate him.

From my last correspondence, some choice phrases, which I have seen similar to
Others, most of which has been covered Ad nauseum!

"Schedule 5 is just a ‘shopping list’ of items, with no corresponding procedures, inspection techniques, limits, tolerances, or component overhaul limits. These specifics are found in the aircraft manufacturers maintenance data, which includes Service Bulletins, etc.."

And,

"LAMES are obliged under the requirements of CAR 42V, to carry out all maintenance in accordance with approved data. In addition, CAR 42V requires the incorporation of approved manufacturer’s instructions irrespective of which maintenance schedule is selected i.e. CAR 42A, CAR 42B or CAR 42C. CAR 42V ensures specific maintenance requirements, as identified by the manufacturer, cannot be ignored by registered operators who have selected CAR 42B CASA Schedule 5."

And,

"you are automatically obliged to follow all of the manufacturers requirements where they exist for specific requirements while signing off the items in Schedule 5."

Now, you can look at it however you wish, but if what your saying is (I think I got at least this much right!) there are no regs that specifically cover and make SB's Mandatory, what I'm telling you is they are referenced to within the scope of the approved Data, our AWI's tell us they are, my CASA contacts say they are, meaning
CASA's overall stance is they are.
That includes references to TCM's many SB, SL, SID, etc etc.
So my point is it doesn't seem so much "What" regulation, even though a fair minded person could look at the reference to all approved Data and take that to mean SB's as well, but "who's", because what I'm being continually told by the guys who are the ones who write the regs and enforce them is it is part of the overall approved Data.
Not sure why they can't use stronger wording than obliged, but there you have it.
The Mag issue should be pretty straight forward due to the SB following so closely the SM requirements, so maybe not a good example.
My goodness it would be so easy if CAR whatever stated MSB's are exactly that, and everything else advisory in nature, but i would hate to try defend not complying with even an advisory
Should anything untoward occur.

[LeadSled]

Perspective,
What we are seeing here is what is wrong with aviation in Australia, commonly referred to as "rule by law", and not "rule of law".

To try and understand the difference, Google Robin Speed and the Rule of Law Institute of Australia, an organisation established by some leading lawyers in Sydney.

To be clear, SIDs are quite distinct to SBs or Sls. The Cessna SIDs are part of the Cessna MMs, making then mandatory under our law.

As for what the law actually says, I could quote a number of my colleagues of the ALAANZ, all of whom have forgotten more about aviation law than yr wotisname and all of his mates put together, and these colleagues have one thing in common, they have never produced a MR in their lives, most of them will have never put a spanner on an aircraft.

Having grease under your fingernails is no qualification to claim definitive expertise in Australia's convoluted, contradictory aviation law?I don't think so.

However, the sad matter is that the AWIs etc have mostly come from industry, and have the same confused idea of what the law actually is, as they have absorbed erroneous shibboleths since apprenticeship days, CASA in-service training doesn't help. Some of it is, legally, quite wrong, some just misleading. I know, I have sat in on some of it, induction training for new AWIs and recurrent for existing AWIs.

The further sad matter is that so many in the aviation field, or GA anyway, in recent years, have come to accept what you would never accept from the police if it was an automobile ---- the imposition of fines and license action ---- based on the opinion of the policeman as to what the law is, as opposed to being based on evidence and the actual law---- and the industry in general has been too spineless to stop what is going on.

Are some of you trying to say that the law, as it applies to SBs, says one thing for GA and another thing for airlines --- because, believe me, incorporation of SBs or SLs is the decision of the Registered Operator in the airline world, not a mandatory requirement. Legally it is the same for everybody.

Yr er er er,
I suggest you update on what "return to service" currently means -now, not what you thought it did, in the past. But you probably had it wrong then, too!!

Just to throw in a bit of burlie, there is a very strong legal case to say that the C.of A of most US made small aircraft on the Australian register are invalid, because they do not conform to their type design.

They are invalid, because the AU C.of A is dependent on the US C.of A being valid, thus the AU Type Acceptance being valid, and that is not the case, because these aircraft are not being maintained in accordance with the type design and manufacturer's instructions for continuing airworthiness.

There is, actually, a way around this problem, how to conduct US acceptable continuing airworthiness programs under Australian regulations.

Just a hint:

"Schedule 5 is just a ‘shopping list’ of items, with no corresponding procedures, inspection techniques, limits, tolerances, or component overhaul limits. These specifics are found in the aircraft manufacturers maintenance data, which includes Service Bulletins, etc.."
If the above came from CASA, I am not surprised, because it, wherever it came from, reveals the lamentable ignorance, practical and legal, of whoever made it. Including the incorrect statement about SBs.

Schedule 5 is, in fact, an almost word for word copy of FAA FAR 43, Appendix D, this is a fact of great significance to having a valid AU C.of A., but it only works if you understand the whole picture.

A Chocolate Frog (figuratively speaking) to the first to figure out the answer.

Tootle pip!!

PS:
because what I'm being continually told by the guys who are the ones who write the regs and enforce them is it is part of the overall approved Data.

That is a widespread opinion in CASA, it is not the law, as enacted by Parliament. I am not exactly short on the experience of developing regulations in this field, perhaps that is why I understand it.

[yr right]

So once again leadie you have not answered one question I gave you.
As for lawyers wtf. They have zero idea and understanding. I proved this in a Australian court of law.
As for the word recommend how come that' different from what I got back from Casa.
You like most that don't get your hands dirty seam to think you know it all. But in reality you actually don't. It one thing to read law another to understand it and yet another to actually use it and have it used against you
You like most are very brave when you don't have to sign anything.
Next under class A. It works on a system of maintenance. In its lbs. you must ADDRESS all sb msb si etc etc etc. also you must have a maintenance controller. Now the lame is NO longer at risk from prosecution if something is missed on the work pak. If you don't do a sb etc you must have a good reason not to. Don't confuse the issue between class a and b. They whist similar they not the same.
And stop quoting FAA req as well. They not as perfect as you make them out to be.

[Eddie Dean]

There you have it, Yr Right, you can sign off your work as Carried out IAW Leadsled and be confident that you don't have to do any SBs. I'm sure Leadsled will go to court with you and dazzle everyone with his knowledge

[yr right]

So once again I'll ask you these questions leadie. You can answer lots or none. That makes it simple for you.

How many lbs have you written
How many aircraft have u placed on the Australian registerer
How many SOM have you had approved
How many M/R have you issued
How many Casa exams have you done in regards to law in the maintenance field.
How many court case have you been evolved with in the case of a maintenance issue.

Next
SIDS are in the m/m but refer to sb. True or not true

Next when did Allianz ever go to bat for an lame.
Next this is the most important of all.
Its because of people like yourself WE as lame have to do as in this example on this thread. Because of people like your self if it dose go pear shape poeple like your self are the first ones that head for a court.

[yr right]

Yeh Eddie I'll try that today. I done this because leadie said it was all good. I run it past our Awi first but lol

[Eddie Dean]

Folks,
See above, that does NOT make a OEM SB on a Class B aircraft component mandatory.Not quite right Folks, it does if the SB refers to an overhaul.
Leadie should also talk to all of those doing mandatory exhaust valve SBs on lycoming piston engines, that they are wasting their time.

[yr right]

The most important thing is what is written in your LBS. even if it says shed 5 it most likely by now also quote sb msb etc have to be done as well. If it doesn't by now you have to change your lbs.

[Jabawocky]

So once again leadie you have not answered one question I gave you.
Yr kidding me……..coming from YOU! The master of never answering sensible straight and direct questions. Unbelievable!!



How many lbs have you written
How many aircraft have u placed on the Australian registerer
How many SOM have you had approved
How many M/R have you issued
How many Casa exams have you done in regards to law in the maintenance field.
How many court case have you been evolved with in the case of a maintenance issue.

Your usual feather ruffling to create an illusion that these very actions somehow make a person an expert at understanding either LAW as it applies,or the laws of physics.

My guess is I have written a few more MR's than Leadsled ever has. A few less than you for sure. But that has nothing do with anything. It just means we know what things to write on a waxy horrible form!

The fact you were grilled in a civil case after a fatal prang, and I agree it was the pilots fault not yours, has nothing to do with knowing what the law says and means. The fact that many CASA FOI's and AWI's do not understand the laws and often screw up application of them is not surprising. But they can't all be correct when some are of differing opinion.

As for what judgements you have seen in court…….well I think we all know they are often flawed as well. And just because you have seen one opinion handed down does not in fact make it correct. Think Azaria Chamberlain.

If the court on the day is convinced by a CASA representative that recommended means mandatory, and the other side does not argue it well enough, then on that day in that court the opinion of one will prevail. Just like the earth was flat for many centuries……until…… :ok: All swans are white…..until they discovered black ones when the west of Van Diemans Land was found. :ok:

[yr right]

So leadie. You have previously stated that SIDS has to be done because it's in the m/m.

Well what about fuild hoses. Etc.

Magnetos note 5 model 210 series service manual states
Slick mags latest revision sb2-80c
Or bendix latest revision sb no 643.
Or is it leadie revision you don't have to worry about that. So what is it. Like going to the supermarket you just pick and choose what ever you wish

[Perspective]

Leadsled, I was referring to "TCM's many SB, SL, SID," not SIDS. But point taken. As I say, if the SB is highlighting the MM requirements it is also by default
mandatory.

[yr right]

Jaba I'll answer the rest of your questions shorty.
But first and foremost this needs to be stated.

I have never been taken to Court for an aviation accident or incident.
In fact the accident I was envoled with I never as the co-ordenting lame and m/r issuer I never got a call from Casa. The police. The Feds. The coroner. No one called me.
This was because of two reasons
1st the employer look after their lames and was a 1stclass maintenance org that done the right thing.
2nd was the maintenance carried out was done right. To the point that the poeple that recovered the wreck over heard basi saying the best condition of the aircraft type that they had seen.
In fact they found only one thing wrong with the aircraft and this was proven to had be done by the owners.
Now I have been called to court for aviation matters. This has been as an expert witness. I gave evidence and I was not the grillee in fact I was the griller. I made the Casa legal team look like a brunch of preschool kids. Why because like you. You treat me with contempt and realizing that although I may have problems with letters that dose not mean my mind is and my abilities are in any way affected. And what did I beat Casa on. Aviation law.

[Frank Arouet]

Don't lead with your chin yr right or the CAsA pre school kids may come knocking on your door to give you some lessons in homework humility.
Regarding dirty fingernails, think about those pre school kids who wrote the bloody laws and how many times they've looked under the bonnet of their Lexus.


EDIT: ELP tests seem wanting in some regard. Do glasses help.

[yr right]

We'll frank. I'm guessing my file has a big red x on it. I have several get out of goal free passes if they ever wish to come along knocking on my door.
One thing is I'm not scared of Casa. I do the right thing always have. They can't say the same. I have that up my sleeve.

[yr right]

Yr kidding me……..coming from YOU! The master of never answering sensible straight and direct questions. Unbelievable!!


As I said to you then and I will repeat myself. I answered nearly all your questions expect the questions where data was required and I didn't have that data in the middle of the desert at that time


Your usual feather ruffling to create an illusion that these very actions somehow make a person an expert at understanding either LAW as it applies,or the laws of physics.

No not ruffled any ones feathers with exception to those misleading with in correct facts.

My guess is I have written a few more MR's than Leadsled ever has. A few less than you for sure. But that has nothing do with anything. It just means we know what things to write on a waxy horrible form!

So dose that mean you have actually issued a m/r

The fact you were grilled in a civil case after a fatal prang, and I agree it was the pilots fault not yours, has nothing to do with knowing what the law says and means. The fact that many CASA FOI's and AWI's do not understand the laws and often screw up application of them is not surprising. But they can't all be correct when some are of differing opinion.


Already answered this question. Perhaps in future you may pm me before you shot yourself in the foot and defame someone.


As for what judgements you have seen in court…….well I think we all know they are often flawed as well. And just because you have seen one opinion handed down does not in fact make it correct. Think Azaria Chamberlain.

If the court on the day is convinced by a CASA representative that recommended means mandatory, and the other side does not argue it well enough, then on that day in that court the opinion of one will prevail. Just like the earth was flat for many centuries……until…… :ok: All swans are white…..until they discovered black ones when the west of Van Diemans Land was found. :ok:

Should it be that way in aviation I think not.

Now leadie by the way. Engine o/h for both tcm and lyc are both SIL and not Sb

[Jabawocky]

You treat me with contempt

i do not treat you with contempt. In fact historically I have tried to engage with you in a sensible and educational manner the whole time. You still never answer any good questions I ask.

[Stikybeke]

Yr Right!!

Just as I suspected...

Now I have been called to court for aviation matters. This has been as an expert witness. I gave evidence and I was not the grillee in fact I was the griller

I made the Casa legal team look like a brunch of preschool kids.

And what did I beat Casa on. Aviation law.

Quite clearly you are not only a LAME but a person who has historically been subjected to court experiences which have no doubt over time collectively enhanced your ability to interpret, analyse and present Aviation law as related to the relevant matter to which you had been called to give evidence as an expert witness to the extent that a court will not only accept your evidence but allow you to be the "griller" I presume of other witnesses.

I can only guess that those witnesses are now better persons as a result of their interaction with you during that process.

I think you are wasted as a LAME and should maybe direct your vast knowledge and experience of aviation related LAME and associated law matters towards the court more often.

Just a thought anyway,

Stiky

[Jabawocky]

And then once he has a law degree and a degree in aeronautical engineering, and built a really fancy engine test facility he can go to the USA and teach the FAA, and George Braly all about it and why the APS class is full of BS. And maybe redesign the Gamijectors, TAT systems and perhaps the Ted Smith Aerostar….which is bound to be designed wrong.

We will have to rewrite 2.5 days of class notes :eek:

Hey Sticky, Two lawyers with aeronautical engineering backgrounds I consider really good friends of mine (you know them ;) ). If your proposal gets legs I might have to add a third. :ooh:

[yr right]

I take it you were referring to the clown that ran and flew his engine with a cylinder with 0/80 even though the m/m says not too. The same person that promotes a course with their own data even though their data is not approved. Promotes a course that is also not approved. Feeds miss truths about engine o/hs. Even though your own wife would not permit an org fly their workers using this data. The same people that will not admit that if the Wyala accident if he only place mixture full rich prop full fine then increased the power lever chances are he would have made it. ( and don't go on that that crank was cracked that is not relevant as it didn't fail).
Then calls me dangerous.
The cynical among us would thing that your Ivory tower was cut down by some two bit hick working in the middle of desert and it has upset the apple cart. And then you go on how you are going to help me. Well David I'm fine. I can think for myself. I see and have to repair the damage that occurs. I'm sorry I'm not a sheep. And I didn't say it at the time. But I was quite disappointed that you use my mate death to further your own cause. That was a real low. Then you accuse someone of having another cause to wind turbines. Even though you never meet or even talk to the person envoled.
You never released an aircraft. You never had your name on that m/r have you.
Yet even on this topic you are telling people not to do something that is required.
You pertray yourself as the grandmaster with aircraft engines. Accused me of not being a good trouble shooter. I gave you the opening to come here and I put myself up against your self. No engine mangment instruments. Just good old feel taste smell. As expected no response from your self. To be expected. Any can be a master when it is delivered on a plate.

So now back ont the issue at hand.
We used to have Ad hose 2 and 3. Now we don't have not had it since the late 90s. So how do we do engine and airframe hose changes and px texts. Or don't we. Because if you use the same thing as with the magnetos then they will never be done. Fact is a SB or Si etc is done so it's easier to change if required. This saves changing m/m.
At the end of the day it's easy to be brave when you take no responsibility and leave it for others to take. As as for your remark about court. So how many times have you been ask and gone to court in defense of someone in an aviation industry.
Some of use do some of use just talk. Which are you.

[Sunfish]

The fact that this thread even exists is representative of the utter damnation that is Australian Aviation regulation, constructed and administered by CASA.

I spent good money on a maintenance regulation course which demonstrated conclusively to me that the regulations applying to maintenance have nothing whatsoever to do with safety. They are more akin to making obeisance to the flying spaghetti monster than attempting to give effect to the James Reason model of holes in cheese lining up.

Some may be surprised that the maintenance systems of airlines have nothing whatsoever to do with CASA, indeed CASA wouldn't even comprehend them (that from current players) and it wasn't much different in my day. CASA doesn't have the skills. experience or talent to regulate Qantas, etc. so they concentrate on easy low hanging fruit.

And CASA still get it wrong… In my opinion after seeing some structure of an aircraft I'd just spent touring for three weeks in…what a mess! And i'd been flying that! Where the f**k were you CASA?

What is wrong with using the FAA regs and removing this criminal liability bull****?

My aircraft is 90% complete, the barriers to first flight are regulatory and may well be insuperable. I have a veggie garden to build, overseas trips beckon and the thought of scenic flights around snowcapped mountains in my own aircraft is starting to drop in priority, in no small part thanks to Pprune.

I threaten my aircraft regularly with a chainsaw because I know that however hard I try to build it as a baby Boeing as I was taught, CASA can always find fault with it…. Fault with criminal penalties for the builder/maintainer.

[Aussie Bob]

I threaten my aircraft regularly with a chainsaw

Please finish it Sunfish! You will get around the hurdles ....

[yr right]

We'll try and work with regs on a daily basis.
Try and make sure you and your staff have done the right thing.
Then try and look after your costumer.
I will add this point as well. The poeple that push the lop courses. Their own words not mine. We have never been sued. So how do you take that. If you bashing your whole field that we never been sued is that good or bad.
We live with that every day. The regs are not clear at all. The been done to please the airlines and ex military personnel that have now taken over Casa. Faa not reqs really not that good. How ever they do issue a plain English set of reqs.
So where dose it leave the maintenance org. We have to do more than we wish. You all think we trying to rip everyone off. Well I challenge some of you to take a week off and go and work at your maintenance org and just see what it is like. Just a thought.
People are brave as I've said when they are not the ones that have to take responsibility for their actions and put pen to paper.
And as for Boeing lets just say they make great aircraft.

[yr right]

Leadie and Jaba
Under the same sb that has the yearly o/h it also states that 500 hourly magneto checks are to be c/o. So I take it you also suggesting that these also do not need to be complied with ?

[Eddie Dean]

It would appear, from reading previous posts, from the various posters on this thread that there are two types posting.
First are private owners who wish to maintain their aircraft to their own interpretation of the CASA regulations and wish to find the cheapest rather than the safest method for that maintenance.
The second are those that maintain aircraft in commercial operations and adhere to the regulations as advised by the AWI responsible for their C of A.

[Jabawocky]

First are private owners who wish to maintain their aircraft to their own interpretation of the CASA regulations and wish to find the cheapest rather than the safest method for that maintenance.

That could apply to some, but not most. I can speak for myself and the original poster here, we can afford and do spend almost limitless amounts on maintenance, brainy even more so than me, but it needs to be understood that throwing cash does not equal safe and at times it achieves the exact opposite.

The second are those that maintain aircraft in commercial operations and adhere to the regulations as advised by the AWI responsible for their C of A.

And the problem there is when there is too many wildly differing opinions of AWI's that do not know how to apply the regulations as per the law (and not their opinion) you get wildly conflicting standards across the country. Hence Brainy's questioning the LAME resulted in that LAME's AWI confirming Brainy's request was valid, and in difference to many on this thread.

When you fix that, and apply appropriate cash……everyone is as safe as practically possible, and happy.

I will respond to "yr rights" disgraceful post above later….when I get time. :=

[yr right]

That will be interesting.

[Frank Arouet]

Compliance means complying with the AWI's opinion of the rules.


It was said earlier that we have rule of regulation not rule of law. This fails to take into account the opinion by the prosecutor of those rules which varies and often to suit an agenda. This means all rules are unworkable.

[yr right]

What's I'm realizing the scary part is Jaba. Not only do you think you know more than the manufacturer but now your willing to go into a SB etc and dissect that data to what you wish or wish not to do. Then apply your views onto everyone else. Heavens above if they don't agree with you.
But easy to be brave when you don't have to sign for it.

[yr right]

Frank.
Remember Ad hose 2 & 3.

Was an Ad so had to be done now what. If you go by this post and what others see as their right. Hose now don't have to be done. Then what a bout fuel pumps. Or vac pumps. So unless their is a AD I guess nothing has to be carried out.
All because Casa is trying to obslove them self of liability.

[Frank Arouet]

I don't know what I'm buying into here, but I'll play a while until I get bored.

If I give you my Maule for an annual inspection I expect that aircraft will be fit to fly and indeed, it may be argued, fit for the next 12 months or 100 hours.

Notwithstanding I have a signed letter from The Deputy Prime Minister/ Transport Minister of the day to say a maintenance release cannot be relied upon to attest to the airworthiness of an aircraft, I maintain it satisfies the requirements of the FOI who may ramp check me to see if in fact I have signed the daily inspection on that document that tells me it is fit to fly... with me so far? Well, I fly off and a hose bursts, oil goes everywhere and... just say, the engine seizes and is a write off... Who am I going to sue?

Correct, the bloke I paid the money to. You as the servant have a duty of care to me to make sure you don't put my life at risk. You carry the can. You are liable. You are the bloke who has this duty, not because CAsA or some other school kid with a Lexus who wrote some laws as to what you can't do instead of what you can do... You mate, buddy... old chap.

Because it's not writ large what you may do, do you assume you don't have to do it?

AD's for hoses in absentia do not an inspection for Mrs Arouets little boy make. It's common law in which court you will find yourself justly explaining things, not the AAT, (which appears to be the only court CAsA practice ((pric-tease)) in).

CAsA have absolved themselves from liability old chap. Nobody can write as many words as that mob and not be free of any liability.

This free advice given by Frank Arouet, Bush Lawyer, CAsA victim, Political Urger and part time Roo shooter and Choko grower.

Use it wisely before the real lawyers stick it up both of us.

[yr right]

Yes frank. It's easy to be brave when you can plam it off to someone else when it goes pear shaped and you never put pen to paper.

[Brainy]

Well this thread has grown malignant little legs of its own…

Surely the LAME's only responsibility is to perform the work requested of them (by the person responsible for the continued airworthiness of the aircraft) to the best of their ability, and for that standard to be competent at least. If it doesn't meet that standard, they are liable for the deficiencies arising and the potential consequences. No more and no less. Similar to my industry, patients are ultimately responsible for their own continued health, they choose whether or not to have a particular operation (there are no mandatory overhauls) and my responsibility is to perform it correctly. If I don't and they suffer impairment or adverse consequence as a result, who is liable? Me, as the person performing the work. Why would anyone lose any sleep over any of that - presumably we all strive to to a good job, and we all keep the insurance industry afloat by paying hefty premiums to insure ourselves. If the registered operator chooses not to follow a non-mandatory manufacturer's SB, the buck should stop with them, not the LAME. I do not believe that the law sees it otherwise. If I recommend that a patient has an operation (I can't mandate it), but they choose not to, they lose control of their car due to their weak arm / wonky eye / insert failed body part here and crash into a school bus full of children with haemophilia, who carries the blame?

I think this thread has reached its manufacturer's specified life limit.

[Frank Arouet]

Hit EDIT DELETE


You have the power. Assume that responsibility as a model to all of us and...touche'

[Eddie Dean]

Surely the LAME's only responsibility is to perform the work requested of them (by the person responsible for the continued airworthiness of the aircraft) Surely you jest. Or misunderstand the intent of the CASA requirements for continuing airworthiness.
I would also be interested in talking to the AWI who told you that only part of SB643 was applicable to your aircraft. PM me his details if it wasn't in confidence, as this is a direct contradiction to both western aust and far north QLD interpretation

[yr right]

And here lays the big problem. The lack of knowledge that the general aviation comunity has with what the legal position of a lame is. Unless it is a class A or in some but not all class B with a maintenance controller the coordination of each category is the responsibility of that certifying lame.
Serval years ago there was a push that ALL maintenance org had a contract with the owner operator that the maintenance org took responsibility for the maintenance of the aircraft. This was to stop exactly this

[Brainy]

Surely you jest. Or misunderstand the intent of the CASA requirements for continuing airworthiness.
I would also be interested in talking to the AWI who told you that only part of SB643 was applicable to your aircraft. PM me his details if it wasn't in confidence, as this is a direct contradiction to both western aust and far north QLD interpretation


Misunderstand perhaps, but jest I do not. However, I am expressing my opinion, not legal fact. I don't expect others' opinions to align with mine, but I'm cool with that. We've had multiple pages of varying opinions, some intelligible some less so, but still not one demonstration of fact that the overhaul of bendix magnetos on calendar time is a mandatory requirement. As to SB643, one does not have to comply with ANY of it. Don't ask your AWI 'do we have to comply with the calendar overhaul of these magnetos?' but rather ask 'are all the manufacturers' SBs now mandatory?'. You might very well get 2 different answers. I have it in writing from CASA that compliance with a SB (that is not incorporated into the aircraft service manual) is not mandatory, and following the advice in the bulletin should be considered by the registered operator, who is responsible for the continued airworthiness of the aircraft. Do you have written advice to the contrary?

[LeadSled]

In its lbs. you must ADDRESS all sb msb si etc etc etc. also you must have a maintenance controller. Now the lame is NO longer at risk from prosecution if something is missed on the work pak. If you don't do a sb etc you must have a good reason not to. Don't confuse the issue between class a and b. They whist similar they not the same. Well, folks, yr rrrr has actually got it right, sort of.
As he says above (effectively) you consider SBs by whatever name but it is not mandatory to carry them out, it is a decision of the Registered Operator. At last he admits SB are not mandatory.

I have made no distinction between Class A and Class B, nor is there a difference as far as SBs are concerned. In fact, legally, every Australian registered aircraft must be maintained to a CASA approved maintenance schedule. You have choices, but in the end, the result will be "CASA Approved".

yr rrrrr wrong,
You have no idea who I am or what my aviation background is, but I can say, without fear of contradiction, I have spent a career signing my name to various bits of aviation paperwork, which carry potentially great personal liability. In general. much greater potential personal liability than anything a LAME is ever going to sign.

Some of that has been very directly maintenance related, and at times I have had to wash my hands so that I didn't get big greasy fingermarks on the MR. Such signatures were and are based on the rights and privileges of my aviation professional qualification.

Brainy,
As I have said in a previous post, you have got it right.

As a matter of interest, yr rrrrr wrong's attitude is rare but far from unique amongst LAMEs.

There is a very interesting Flight Safety Foundation study of attitudes of ATC, pilots and LAME in Australia, the mutual contempt each group has towards the other two is quite unique to Australia, just another part of the reason why Australia has a such a poor air safety record, compared to the USA.

I think yr rrrr wrong probably has a balanced personality. a chip in both shoulders.

Somebody said: " You are entitled to your own opinions, you are not entitled to your own facts". Clearly, many in the aviation field believe they are exempt from this fact.

Tootle pip!!

[yr right]

We'll bill I know more about you than you think. your previous job is the is indicative of your agorance but that's to be expected.

[Horatio Leafblower]

Was an Ad so had to be done now what. If you go by this post and what others see as their right. Hose now don't have to be done. Then what a bout fuel pumps. Or vac pumps. So unless their is a AD I guess nothing has to be carried out.

What does the OEM say?

Is there no data from the manufacturer? :ugh:

[LeadSled]

Yr rrrrr wrong,
I'll take educated arrogance over ill educated ignorance any day of the week.
You really are an outstanding example of the FSF findings.
Tootle pip!!

[Pinky the pilot]

I think this thread has reached its manufacturer's specified life limit.

I tend to agree. BTW, I am only a Pilot, not a LAME or an AME.

[yr right]

Whilst the actual difference in maintenance between certain aircraft on ether class A or B may be similar. The certifcation and the record keeping between the two is chalk and cheese. So Bill you are totally incorrect.
As for doing Sb it's clearly defined in the caap.
Also your account for not doing SB in class A once again is in correct.
I have never seen a class A aircraft lbs that's omits doing Sb etc.
as you keep going on about the difference in safety between USA and Australia please define. Don't place maintenance safety in with flying. Maintenance here is as safe if not better than the USA. And yes I been and worked in the USA as well as other countries.
And considering some of what that's come out of the states it's a wonder they even fly.

[yr right]

Well bill that's your choice. But your just typical of type. I'm happy to stand by repartition and my knowledge in the industry. If I was sooooo bad I guess I would not still be working in the industry especially 35 odd years after I started. And gee I sure I would have been pulled up by Awi's by now. Bugger me I haven't.
And you being where you was. I leave you with one word. Bates.

[Eddie Dean]

Is there no data from the manufacturer?Yes Horatio, that would include the Service Bulletins and Service Instructions

[Horatio Leafblower]

Yes Horatio, that would include the Service Bulletins and Service Instructions

In which case, why is there any debate? :confused:

[yr right]

In which case, why is there any debate? :confused:

Because people are brave when they don't have to sign for it. That's why !

[mendi63]

The first paragraph of SB643B states:

The following information constitutes the manufacturer’s Instructions for Continued Airworthiness and outlines required maintenance, inspection, cleaning and overhaul intervals of the TCM and Bendix magnetos and related equipment listed under "EquipmentAffected" (my bolding).

Whilst it is a few years since I worked with Australian Rules, I cannot see how a LAME can get around that statement. Where I work that means I am obliged to comply with the SB.

[jas24zzk]

I always understood CAAP's to be an advisory publication. You should consider it, but you don't HAVE to comply

[Eddie Dean]

I have it in writing from CASA that compliance with a SB (that is not incorporated into the aircraft service manual) is not mandatory,Missed that Brainy, could you please post it here so you can alleviate all argument about it.

[LeadSled]

----- as you keep going on about the difference in safety between USA and Australia please define.

yr rrrrr wrong,

The published statistics, using publicly available figures, are quite clear, and indeed the deterioration in the Australian GA record compared to the US has recently been remarked.

Using ICAO stand definitions for accidents and incidents, Australia's GA accident rate has deteriorated, in the last 15 years, from double the US rate to three times the US rate, in round figures.

The changes are so clear and distinct that any arguments about "statistically insignificance " cannot be sustained.

I have no intention of putting the HC transport here, look it up for yourselves, suffice to say that in every statistical category, the US produces the world's best aviation safety outcomes, and has done for years.

They must be doing something right.

I note with some interest that nobody has taken up my challenge as to whether many Australian C.of A are valid. All you blokes talking about liability for signatories, I would have thought that signing out an MR if the C. of A was not valid would have raised some liability concerns.

Tootle pip!!

[Perspective]

Interesting Leadsled re statistical differences of accident rates US to here,
You would have to get a pretty detailed breakdown I would imagine to identify
Any underlying reasons, (I know stating the obvious), lack of hours-currency? Do they include LSA in their figures?


Oh Man..this goes on and on! (I feel a collective Sigh there somewhere!)
It seems no matter what document, link or CASA reference, Reg, advisory, letter, Order or publication that gets posted here, advising, obligating, obliging, insinuating, inferring or directing you to carry out tasks I.a.w. The approved maintenance data, along with our AWI's and senior Engineers directions (and yes Brainy, correspondence) and enforcement of said Data, Regs etc, I can't believe there exists such a strong belief that the inference is that these things need not be either referred to or followed, or would not attract some legal ramification.
Put simply, if you can show me anywhere where it simply breaks down and states in clear, unambiguous black and white writing, an SB, as apposed to an MSB is approved Data, but one I must comply and one is optional, I'll send you flowers.
I can read, (barely) I know one states Mandatory and one just SB. Obviously. but the regs don't break the compliance down to anything simpler than All Approved Data.
The Mag is a bad example due to it being in and per the MM anyway.
Take for instance, as an example, just two of many directions,

1,-3.4 The procedures specified in the approved maintenance data detailing how maintenance is to be performed must be complied with when using the CAA Maintenance Schedule.

2,-6-6.1 If it is clear from the terms of the manufacturer’s requirement that the manufacturer considers compliance is optional, then that requirement is optional.

So no probs, I'll just go to that approved Data for that Piper Arrow I'm maintaining to see if they give me an option, in the Data, which I've been directed to, god knows how many times, in the Data, clear and concise please,
So I get to Paragraph 3-8 under special inspections section,

SERVICE PUBLICATION COMPLIANCE REQUIREMENTS. Piper service Publications are recommended and/or Mandatory changes to piper aircraft. "Piper service bulletins are of special importance and Piper considers compliance mandatory.

Did they mean all, some, FFS Piper!

Look for any other wording or inference in the MM for clarification, find under
General in their own Table of Insp in the sign off, general, "All manufacturers service bulletins and letters complied with" FFS.

It is clear by those two statements alone that piper consider SB"s and even SL's mandatory. They just referred to it twice, and probably more, That's in the approved maintenance Data that I have had to refer to.

Someone stated it's the Regs that seem to be unworkable, and in the current format maybe they are.
You may be a master of Law, but I find it hard to believe that when so much Wording and direction from CASA and the manufacturer, states in black and white we must use, follow and abide by the limits set out and approved by the manufacturer, that for me to knowingly not follow that is anything other than negligent.

I can take being called a muppet but find it hard to understand how one can speak from such a position of superiority and confidence and advice to non-conformance with such matters as CASA regulation, when so much Data and direction exists to state the opposite, someone even suggesting we grow some Balls. Nice.
I'm happy to talk about a common sense approach to maintenance so long as it stays within the requirements of the Regs, as they stand, as they are understood or interpreted by my delegates and as they are enforced by them,
However you want to term it.

[yr right]

I always understood CAAP's to be an advisory publication. You should consider it, but you don't HAVE to comply

Well jaz you a quite correct. Yes a caap is not law. But couple that with the LBS and it is. If you elect to do shedule 5 it will be on your log book statement which now you have to do it IAW. This now makes the caap a legal document. As the caap state how to do shed 5. I would like to see anyone try and make a defense against that in a court. And this is what the problem is. While all the parts are flying in formation it's when it dose not the problems arise. They start at the front and stop at the rear nav light. Everything is looked at. You will be charged on anything that is not right.
Someone earlier said on how the judge feels on the day. Wrong. They have rules as well. And as for the word recommend as I've said before in court that means you have to do it. Why because it's already gone to court and that's what was determined.

[yr right]

[QUOTE=LeadSled;9006627]Well, folks, yr rrrr has actually got it right, sort of.
As he says above (effectively) you consider SBs by whatever name but it is not mandatory to carry them out, it is a decision of the Registered Operator. At last he admits SB are not mandatory.

I did not say that. I said you address the SB. That means you look at it. Your aircraft s# may not be affected you then have addressed the sb. Please tel me why in the later Casa log books book # Da 3196 is in it. Non recurring Ad si and mods cert log book.


I have made no distinction between Class A and Class B, nor is there a difference as far as SBs are concerned. In fact, legally, every Australian registered aircraft must be maintained to a CASA approved maintenance schedule. You have choices, but in the end, the result will be "CASA Approved".

No you don't under class A

yr rrrrr wrong,
You have no idea who I am or what my aviation background is, but I can say, without fear of contradiction, I have spent a career signing my name to various bits of aviation paperwork, which carry potentially great personal liability. In general. much greater potential personal liability than anything a LAME is ever going to sign.
No your wrong. I do. And let's say you don't no me. And you have no higher level of certifcation than I do. A red stamp dose make it higher.

Some of that has been very directly maintenance related, and at times I have had to wash my hands so that I didn't get big greasy fingermarks on the MR. Such signatures were and are based on the rights and privileges of my aviation professional qualification.

Which means you are not a lame.

Brainy,
As I have said in a previous post, you have got it right.

As a matter of interest, yr rrrrr wrong's attitude is rare but far from unique amongst LAMEs.

Because we have to look after our own interests.

There is a very interesting Flight Safety Foundation study of attitudes of ATC, pilots and LAME in Australia, the mutual contempt each group has towards the other two is quite unique to Australia, just another part of the reason why Australia has a such a poor air safety record, compared to the USA.

I think yr rrrr wrong probably has a balanced personality. a chip in both shoulders.

Um sorry wrong again. No chips at all. But extremely balanced. I would not be ask to do things I've done if I wasn't.

Somebody said: " You are entitled to your own opinions, you are not entitled to your own facts". Clearly, many in the aviation field believe they are exempt from this fact.

Do you include yourself in this ?

[yr right]

So what is a SB.
It's a means of two things.
It's a way of the manufacturer limiting liability if you don't do something as they have asked.
Next it's a way to bring defects that need to be addressed to the market quickly and easily.

In the old days and forget anywhere else in the world but here. They were addressed and if Casa thought they was of merit they were made into a AD. This meant that SB didn't have to be complied with. This option is no longer valid.
The owness is now on the certifying lame. Their is no paper work that an owner can say yes or no and the lame be protected.
Now we have country of origin ADs. If you every won't to see how we become useless go to Casa site. Ads. Equipment. Restraint equipment. 2013-0020R4.
Then tell me and the rest of use how to compily with this AD here in Australia.

[yr right]

And Bill. You state that SB are also not manitory in Class A which is wrong.
Please remember a major airline that is no longer with us in around 2001 that got all sorts of trouble for not caring out SB on it 767. Or is that just another made up fact by myself.

[Perspective]

Interesting article, with some choice phrases to boot!

http://www.casa.gov.au/wcmswr/_assets/main/fsa/2004/apr/36-41.pdf

For an airline SB that's apparently not mandatory, it sure was applied as such!

"Ansett consulted CASA and Boeing on the best way of making up the inspections. The end of April was the deadline to complete them".!

[yr right]

Yes prospective I was clearly wrong.

[Perspective]

Not really what I was saying yr Rgt,
The comment was made previously about airlines having their own requirements, but even with their own robust SOM's, they were made to comply,

"Details were required to be provided when manufacturers’ recommendations were acted upon and a full technical justification recorded when they were not"

After I was informed we had to comply with mfg Data Bla bla, the comment was also made to me that any devience from such requirements, required justification from the CofR holder, but would not exclude my obligations or
Responsability.

We used to joke that it seemed every single SB, Mod, whatever was incorporated on our fleet as directed by Boeing, maybe to avoid what happened to Ansett and to avoid,
"CASA warned Ansett of its intention to issue a notice giving Ansett 14 days to show cause why its air operators certificate and certificate of approval should not be withdrawn"

The challenges facing Ansett were obviously far wider and bigger than just this issue, but highlights how CASA approached them in this particular regard.

[Lead Balloon]

From the very article you cited, yr right and Perspective:CASA recognised the seriousness of the Boeing alert service bulletin. While the US Federal Aviation Administration at that time had not issued an airworthiness directive mandating the alert service bulletin, CASA took action to mandate the service bulletin in Australia. The FAA followed suit.In other words, the regulatory position was (and remains) precisely as LeadSled has described, and you r both rong.

*

[yr right]

I have never seen or written a LBS or heard of one ether in a class A aircraft that dose not let you NOT do a SB etc. that was the point.
The point with chance it with ansett was an extreme result. I also did not say that was the only thing that caused the collapse of this airline. However it shows what I said about SB etc. that was the point i was making

[yr right]

From the very article you cited, yr right and Perspective:In other words, the regulatory position was (and remains) precisely as LeadSled has described, and you r both rong.

*


Um bill. It was mandated by an Australian AD. It didn't mandate the SB. It mandated an Ad which in its frame work mandated the SB. This was normal practice at that time. Now Casa would not make it an Ad it would come out as a country of origin AD. That is unless an extremely urgent Ad is required then it may be implemented by an Australian Ad.
However as I have said SB have to be done on Class A aircraft.

But nice diversion bill. And yes it says different but we know it's you.

[Lead Balloon]

I have never seen or written a LBS or heard of one ether in a class A aircraft that dose not let you NOT do a SB etc. that was the point.
The point with chance it with ansett was an extreme result. I also did not say that was the only thing that caused the collapse of this airline. However it shows what I said about SB etc. that was the point i was makingJust goes to show the limits of your knowledge and experience.

[Eddie Dean]

Ansett .......received a service bulletin from Boeing two years earlier notifying the airline that the 767s needed to undergo the inspection on reaching 25,000CASA recognised the seriousness of the Boeing alert service bulletin. While
the US Federal Aviation Administration at that time had not issued an airworthi ness directive mandating the alert service bulletin, CASA took action to mandate the service bulletin in Australia. The FAA followed suit
SO English comprehension isn't your forte there Lead Balloon.
To help you, the sequence was that ANsett missed the SB and then CASA took enforcement action, sometime later they raised an AD

[Perspective]

Boeing. Boeing alert SB. IF the Boeing SB stated optional, then so be it, but what about FAA regs, Boeing's maintenance Req. And compliance therein along with how ever Ansett's SOM was written under CASA's Reg's.
If Piper states optional?
Please read the whole article. Is it not one of the things that led to its grounding.
It's show cause? It's obligations? It did not have robust engineering direction not to comply. does the excerpts from Piper MM mean optional, they consider compliance Mandatory. All SB's. The very data im directed to, not boeings, for that read the 767 MM for me and let me know.

[Lead Balloon]

SO English comprehension isn't your forte there Lead Balloon.
To help you, the sequence was that ANsett missed the SB and then CASA took enforcement action, sometime later they raised an AD

Are you picking on my inglish or my facts. ... seems like I'm unfairly matched by your mastery of everything.

[Eddie Dean]

seems like I'm unfairly matched by your mastery of everything. Pleased that you can admit your failings

[Jabawocky]

Re the Ansett issue and SBs...

From the very article Perspective and yr right are referring to:

CASA recognised the seriousness of the Boeing alert service bulletin. While the US Federal Aviation Administration at that time had not issued an airworthiness directive mandating the alert service bulletin, CASA took action to mandate the service bulletin in Australia. The FAA followed suit.

In other words, the regulatory position was (and remains) precisely as LeadSled has described.

[yr right]

So please inform us why Qantas that had the same aircraft had not the same problem.
You seam to pick and choose what you wish to see.
The problem was tha ansett didn't do what the were suppose to do and that forced Casa hand. Nothing to do with what bill said at David. Please get it right.
This is no different to any SB ever before the change over.

[QFF]

One advantage of having a plain English rule-set is that we would know EXACTLY what the status of a Service Bulletin is and there wouldn't be 9 pages of children arguing in a playground about how their daddy is bigger than yours...

Surely knowing exactly where we stand and the productivity that goes along with it would make up for the lack of entertainment from posts like these if we had said plain English rules...:}

[yr right]

Honestly David you have more spin than a Labour Party politician. The ability to twist anything in your fav our never stops to amaze.

[Jabawocky]

OK, slight thread drift.

Manufacturer has some published data. Yet, when the manufacturer gets your "thing" they adjust it to a value that is around 7-13% higher value. (This could be voltage, oil pressure, fuel pressure or any other thing) They do this work in their very own service centre and return it to service for you. They do it for a good reason, known to them and many others but it is outside the published data sheet.

What do you do?

A: Leave it alone as they set it up as part of their service work and signed it out
B: Reduce the level to the data sheet despite knowing it is better to have it where the OEM set it.
C: Start adopting the same practise yourself as it makes sense?
D: Ask someone at CASA?

[yr right]

One advantage of having a plain English rule-set is that we would know EXACTLY what the status of a Service Bulletin is and there wouldn't be 9 pages of children arguing in a playground about how their daddy is bigger than yours...

Surely knowing exactly where we stand and the productivity that goes along with it would make up for the lack of entertainment from posts like these if we had said plain English rules...:}

I and every other lame and workshop would totally agree with that however we don't. We can't even get two of the same answers from Casa. So after talking to a few friends over the past week most if not all are of the same opinion. It's fine if you do t won't to do. But how ever we are unable to do that. Please feel free to take your work else where. And that folks is just it. Toot toot toot

[Jabawocky]

Steve……. no spin whatsoever….just COPY and PASTE.

You have called me a moron before, and that did not offend me but an ALP pollie…….Be careful, I can afford expensive law suits for defamation :ok: (That is the que to have a smile and not a genuine threat of lawyers on your door)

[Eddie Dean]

Jaba et al, can you not see that Ansett 767 were grounded for NOT carrying out the SB and then CASA raised an AD
In answer to your hypothetical Jaba, contact the OEM and ask questions

[Lead Balloon]

Eddie

If you read the article at the link in Perspective’s post #165 and conclude:

- Ansett was grounded because they didn’t carry out the SB, and

- Ansett was obliged under the regulations to carry out the SB, absent the AD

you sir/madam are illiterate.

[Eddie Dean]

Lead balloon or lead sled who ever you are, I suggest you re read the article, it explicitly says that CASA raised the AD later than the grounding of the 767 aircraft

[andrewr]

Another quote from the linked article:

"An alert is the highest level of Boeing SB, and although it is not compulsoryto comply (as it is with an airworthiness directive)..."

[Stikybeke]

Yr Right,

I'm a bit surprised that after following your response to these posts with regards to your obvious knowledge and experience of all things LAME and related legal requirements that you have possibly overlooked (or chosen for whatever reason) not to share a couple of things.

Maybe this has been as a result of your experiences gained as an expert witness in courts over the years however but it's a bit difficult to tell as there is no further detail with regards to your experience in this regard as to what types of courts you've been involved with aside from being not only an expert witness but the griller of (I presume) other witnesses and your interpretation of the word "recommend" (which is fair enough as you have alluded that it was accepted by the court due to a previous determination).

Maybe to relate this to the thread topic in relation as to what would happen if a fatal accident should occur in the event of a mechanical failure of some sort which has occurred following compliance or non compliance with an AW requirement, MR or SB (or whatever) by a person so authorised to effect that compliance (or non- compliance) could I suggest the following hypothetical situations.....

1. In the first instance I would imagine that regardless of where in Australia an incident or accident has occurred that as because there has been loss of life the matter will go before a coroner whose responsibility it is to determine Identity (of deceased), Date (the death occurred), Place (the death occurred) and manner and cause of death. The first few are easy ones but manner and cause of death is where things get interesting as generally speaking rules of evidence do not apply in Coroners courts.

2. In the event that evidence was identified during any subsequent process that such failure occurred directly as a deliberate act (that is a person or persons knowingly installed a faulty part or knowingly did not maintain something to required, and I would suggest to accepted published industry standards) by a person or persons then that would probably amount to a criminal act whereby the evidence supportive of this act would have to be proved beyond a reasonable doubt, which is the standard by which criminal courts operate and rely upon for determination. In such a case the matter would be referred by the coroner to the relevant DPP for a legal advising and identification of an appropriate course of action.

3. In the event that this doesn't happen and say, the relatives of the deceased, decide to pursue matters further then the option is open for address within the civil legal system. At civil standard the balance of probabilities is the test which means that this (the event that is before court) probably happened. On the other side though a civil court can determine that it probably did not happen and it was nobody's fault and that all appropriate and proper actions were taken by the person or persons responsible in an genuine attempt to comply etc.

4. If this involved a company of course then there is always the option of insolvency, the decisions of which can always be tested by the Administrative Appeals Tribunal if so desired. If the company or person or whatever acted as a result of a decision made by an Australian Government Minister and that decision is to be disputed the AAT is where you go to do that. As we all know, the AAT deals with matters that relate to Civil Aviation and of recent times has been quite thorough with its examinations in matters that have involved not only the company concerned but also of the regulator. Their results are recorded as being fair and impartial.

Now I don't know much about this stuff however from what I read I guess at the end of the day, as far as I can see, it comes down to a question of compliance or a decision of non-compliance which may or may not have an adverse outcome.

Even with your vast experience you should not discount the views offered by the likes of Brainy, Leady, Jabba, Creamie, Eddie, Perspective and others. They are all entitled to their interpretation and spin on things and I think the acknowledgement and courtesy that they know what they are talking about in their various fields would not go astray. Like you, they've all earnt it and their knowledge and input is just as valid as yours.

Remember, you're an expert witness. An expert witness respects the views of others and takes them into consideration before response.

Thanks for reading,
Stiky

[Lead Balloon]

Clearly the people who wrote the Ansett article have no clue.

The operator was already obliged under the regulations to carry out the SB, eh yr right? Therefore, there was no need for CASA to “take action to mandate the SB in Australia”.

And “the last straw for CASA” wasn’t the “incorrectly stowed – and therefore inoperative emergency exit slide” on an aircraft that had flown “for eight sectors before the fault was discovered”.

And that “last straw” wasn’t the basis on which CASA “grounded the entire fleet of ten Boeing 767s.”

And another of those straws wasn’t the B767-300 that “had been incorrectly fitted with a leading edge slat from a B767-200”.

What actually happened was that CASA grounded the entire fleet of ten Boeing 767s because Ansett had not carried out the SB. Isn’t that right, Eddie?

[Perspective]

Well fortunately were talking about Bendix mags andrew, the periods of maintenance which is set out in the MM, as highlighted in the SB, maintained under the CASA regs, enforced by and audited by their surveyors.
I find it it perplexing that people are using an example whereby an SB was missed, under which the airlines own SOM would have directed it to have been addressed either way, the result of which summoned an enforcement by CASA of said SB with threat of grounding, followed by the AD, for a defect that had the potential of a major disaster. If you want to give me an example whereby the SB shouldn't be observed this one is definitely not it.

[Eddie Dean]

What actually happened was that CASA grounded the entire fleet of ten Boeing 767s because Ansett had not carried out the SB. Isn’t that right, Eddie? This is a typical example of a strawman argument, you present something I did not say and tempt others to argue that strawman premise.

[Sunfish]

If you actually read the ATSB report on Ansett between the lines, you understand that Ansett had cut so far into its maintenance planning and fleet oversight function that it could not prove that ANY of its fleets aircraft were in compliance with its system of maintenance.

I challenged Toomey on this on ABC talkback radio at the time of the B767 grounding and he flatly denied he had a problem. Four days later……..

[yr right]

Yr Right,

I'm a bit surprised that after following your response to these posts with regards to your obvious knowledge and experience of all things LAME and related legal requirements that you have possibly overlooked (or chosen for whatever reason) not to share a couple of things.

Maybe this has been as a result of your experiences gained as an expert witness in courts over the years however but it's a bit difficult to tell as there is no further detail with regards to your experience in this regard as to what types of courts you've been involved with aside from being not only an expert witness but the griller of (I presume) other witnesses and your interpretation of the word "recommend" (which is fair enough as you have alluded that it was accepted by the court due to a previous determination).

Maybe to relate this to the thread topic in relation as to what would happen if a fatal accident should occur in the event of a mechanical failure of some sort which has occurred following compliance or non compliance with an AW requirement, MR or SB (or whatever) by a person so authorised to effect that compliance (or non- compliance) could I suggest the following hypothetical situations.....

1. In the first instance I would imagine that regardless of where in Australia an incident or accident has occurred that as because there has been loss of life the matter will go before a coroner whose responsibility it is to determine Identity (of deceased), Date (the death occurred), Place (the death occurred) and manner and cause of death. The first few are easy ones but manner and cause of death is where things get interesting as generally speaking rules of evidence do not apply in Coroners courts.

2. In the event that evidence was identified during any subsequent process that such failure occurred directly as a deliberate act (that is a person or persons knowingly installed a faulty part or knowingly did not maintain something to required, and I would suggest to accepted published industry standards) by a person or persons then that would probably amount to a criminal act whereby the evidence supportive of this act would have to be proved beyond a reasonable doubt, which is the standard by which criminal courts operate and rely upon for determination. In such a case the matter would be referred by the coroner to the relevant DPP for a legal advising and identification of an appropriate course of action.

3. In the event that this doesn't happen and say, the relatives of the deceased, decide to pursue matters further then the option is open for address within the civil legal system. At civil standard the balance of probabilities is the test which means that this (the event that is before court) probably happened. On the other side though a civil court can determine that it probably did not happen and it was nobody's fault and that all appropriate and proper actions were taken by the person or persons responsible in an genuine attempt to comply etc.

4. If this involved a company of course then there is always the option of insolvency, the decisions of which can always be tested by the Administrative Appeals Tribunal if so desired. If the company or person or whatever acted as a result of a decision made by an Australian Government Minister and that decision is to be disputed the AAT is where you go to do that. As we all know, the AAT deals with matters that relate to Civil Aviation and of recent times has been quite thorough with its examinations in matters that have involved not only the company concerned but also of the regulator. Their results are recorded as being fair and impartial.

Now I don't know much about this stuff however from what I read I guess at the end of the day, as far as I can see, it comes down to a question of compliance or a decision of non-compliance which may or may not have an adverse outcome.

Even with your vast experience you should not discount the views offered by the likes of Brainy, Leady, Jabba, Creamie, Eddie, Perspective and others. They are all entitled to their interpretation and spin on things and I think the acknowledgement and courtesy that they know what they are talking about in their various fields would not go astray. Like you, they've all earnt it and their knowledge and input is just as valid as yours.

Remember, you're an expert witness. An expert witness respects the views of others and takes them into consideration before response.

Thanks for reading,
Stiky

Wtf. So who pays for legal representation in all of this. Why should myself or anyone else that releases an aircraft have to face this because some owner that dose not wish to have a SB with absolutely zero back up from Casa be forced to carry the industry. No. What's happening now is if you don't wish to do it that's fine it's your choice. But it's our choice not to issue you with a M/R and ask you to take your work else where.
The maintenance org or lame should not be in anyway held responsible for an accident for inadequate reqs and that's the problem. Aircraft maintenance is built on proactive maintenance not reactive.

[Stikybeke]

I agree with you Yr Right.

I thought however in your experience as an expert witness in courts that you would be across who pays for legal representation etc. As you would know if you are called in that capacity by a court then such representation is provided by the court so that shouldn't be an issue for you given your knowledge and experience.

If however you are a lay person that does'nt have the benefit of your exposure in this regard then that's why you or the company you work for have insurance. If you've done nothing wrong you have nothing to worry about and your insurance will back you.

If however you knowingly do something wrong and that can be proved that when you did or didn't do it you knew that your actions or inactions would have a life threatening result then problem could possibly belong'em you big time.

As for an individual's choice whether to take due regard to issues of compliance then that is up to them. As you've often stated an individuals choice concerning the safety of loved one's being carried in a poorly maintained aircraft can only rest with the person concerned. It's a choice that would surely weight heavily on anyone's mind. I strongly doubt that any of the posters on this thread would fall into that category.

I'm guessing that Scheduled maintenance as per MR / AD requirements would be a form of proactive maintenance when coupled with SB's across the board as opposed to reactive (unscheduled) maintenance if I follow your drift correctly in which case your quote:

Aircraft maintenance is built on proactive maintenance not reactive.

Is quite relevant and quite accurate I would hope.

Stiky

[Lead Balloon]

I find it it perplexing that people are using an example whereby an SB was missed, under which the airlines own SOM would have directed it to have been addressed either way, the result of which summoned an enforcement by CASA of said SB with threat of grounding, followed by the AD, for a defect that had the potential of a major disaster. If you want to give me an example whereby the SB shouldn't be observed this one is definitely not it.Again, clearly the people who wrote the Ansett article had no clue what they were talking about. They forgot to put in the paragraph that said: "The airline's approved system of maintenance required the SB to be carried out, and having not carried it out, the airline was in breach of the regulation requiring the airline to carry out maintenance in accordance with the approved system of maintenance. But CASA was not satisfied that this level of compulsion was sufficient, so CASA issued an AD to compel Ansett to do something it was already compelled to do."

The FAA and CASA left the airlines to decide, and continue to leave the airlines (and everyone else) to decide, what to do about SBs. That concept applies to all SB's, including ones applicable to humble ol' Bendix magnetos.

In the case of the 767 engine pylon SB, however, the FAA and CASA eventually came to the realisation that compliance should be mandatory rather than a matter of choice, and issued an AD. That's what ADs are for. That's not what SBs are for.

Strawman argument, Eddie? So are you now saying that CASA didn't ground Ansett because it failed to carry out the SB? What do you say is the basis on which CASA grounded Ansett?

[yr right]

I agree with you Yr Right.

I thought however in your experience as an expert witness in courts that you would be across who pays for legal representation etc. As you would know if you are called in that capacity by a court then such representation is provided by the court so that shouldn't be an issue for you given your knowledge and experience.

If however you are a lay person that does'nt have the benefit of your exposure in this regard then that's why you or the company you work for have insurance. If you've done nothing wrong you have nothing to worry about and your insurance will back you.

If however you knowingly do something wrong and that can be proved that when you did or didn't do it you knew that your actions or inactions would have a life threatening result then problem could possibly belong'em you big time.

As for an individual's choice whether to take due regard to issues of compliance then that is up to them. As you've often stated an individuals choice concerning the safety of loved one's being carried in a poorly maintained aircraft can only rest with the person concerned. It's a choice that would surely weight heavily on anyone's mind. I strongly doubt that any of the posters on this thread would fall into that category.

I'm guessing that Scheduled maintenance as per MR / AD requirements would be a form of proactive maintenance when coupled with SB's across the board as opposed to reactive (unscheduled) maintenance if I follow your drift correctly in which case your quote:



Is quite relevant and quite accurate I would hope.

Stiky

I'm sorry but I think you missed the point.
The objective is to provide a high level of maintenance and hence keep myself out of the court system.
One case we one it still cost over $30k to prove that we was right. And this was just a case of a vindictive Awi no
Accident no incident. Who paid for that. My mate paid for that. I have my time for free. I don't get your point at all. The objective is not court. Court is a failure. There are no winners everyone pays except Casa. That's why I've previously said that they need to held accountable for their actions.
So what if I'm deamed to be a fault because I didn't do a SB because the owner didn't won't to do it. Why should I and when I say I I am talking about ever lame have to take that responsibility for someone else desire to do a particular job. So at what stage do I stop doing maintenance. If I make a mistake then that's my responsibility not yours if you make that mistake why should it be mind again. Because if I release it then I am saying the aircraft is in a fit and proper state for flight. Not you.

[Jabawocky]

OK, slight thread drift.

Manufacturer has some published data. Yet, when the manufacturer gets your "thing" they adjust it to a value that is around 7-13% higher value. (This could be voltage, oil pressure, fuel pressure or any other thing) They do this work in their very own service centre and return it to service for you. They do it for a good reason, known to them and many others but it is outside the published data sheet.

What do you do?

A: Leave it alone as they set it up as part of their service work and signed it out
B: Reduce the level to the data sheet despite knowing it is better to have it where the OEM set it.
C: Start adopting the same practise yourself as it makes sense?
D: Ask someone at CASA?

Eddie responds with In answer to your hypothetical Jaba, contact the OEM and ask questions

Thats a great idea and it was deliberately not an option offered because the OEM knows and tells you that their setting is better than the book and for good reasons.

So……what do you do now (In Australia)?

[Eddie Dean]

So……what do you do now (In Australia)? I'm still going to contact the OEM and get a definitive answer to the new setting. They cannot alter any data without approval.
If they don't have approval I guess it is a moot point.
Problem arises in that I can't alter the setting unless I have approval on my CofA for the component overhaul, discussions with CASA would have to take place.
Further thoughts, volt regulator is set IAW Aircraft maintenance manual same as fuel pressures etc, so may be able to alter IAW aircraft data rather than the equipment data.

[jas24zzk]

Quote:
Originally Posted by jas24zzk View Post
I always understood CAAP's to be an advisory publication. You should consider it, but you don't HAVE to comply
Well jaz you a quite correct.

Its Jas....as in Jason...no Z in that name.

Yes a caap is not law. But couple that with the LBS and it is. If you elect to do shedule 5 it will be on your log book statement which now you have to do it IAW. This now makes the caap a legal document. As the caap state how to do shed 5. I would like to see anyone try and make a defense against that in a court.

I have spent more than enough time in court, on both sides of the fence.... The fact that the CAAP is what it is, and ADVISORY PUBLICATION, means it cannot be enforced in a court of law. It is a dumb lawyer that loses a case where a CAAP is attempted to be enforced.

As an example, CAAP 92-1 deals with ALA's. Try to find an ALA that complies with it in its whole......NONE do. If it was enforcable in a court of law, then CASA would have closed most airfields in Oz.

Coupling Sched 5 to a CAAP means that your 'lack of maintenance' is only restricted by CASA AD's and the manufacturers Publications.

Someone earlier said on how the judge feels on the day. Wrong. They have rules as well. And as for the word recommend as I've said before in court that means you have to do it. Why because it's already gone to court and that's what was determined

Wrong. The Judge see's it as reccomend. He/she realises there are valid reasons not to do the reccomendation. You only need show cause as to why that recomendation was not followed. It does come down to quality of lawyer.

The bigger problem, is that CASA takes such matters to the AAT, rather than the courts, where normal rules of evidence and prudence do not apply.

-----------------------

A small rule change would ruin CASA in the AAT. Simply forbid the AAT from reviewing matters that have Strict Liability applied. That'll knuck em.

[LeadSled]

jas24zzk,

Well said.

Folks,

Just to attempt to clear something up --- whether it is a CAAP or an AC, it is an acceptable means of compliance, one way of putting it is that it is one way, but not the only way of complying with the regulation, to which it refers.

I find it very difficult to conceive of the situation where a LBS can make a CAAP L-A-W law, except in the opinion of bush lawyer AWIs and LAMEs.

After all, it is just an election as to which of the three possibilities to which a Class B aircraft can be maintained, and before yr rrrr wrong jumps on the bandwagon, the choice is the choice of the registered operator, not the LAME.

Still, not one of you has taken up the challenge of figuring out why many Australian C.of As may be invalid, because the airframe does not comply with the manufacturer's instructions for continuing airworthiness --- how or why does this come about, and what can you do within Australian law to make certain that it does not apply to you aircraft. Not even yr rrr wrong has told me I am wrong about the C.of A matter!!

Don't wait until you are in court fighting an insurance company over a refused payout for a damaged aircraft.

Tootle pip!!

[Lead Balloon]

POH? :confused:

[Perspective]

In order.
CAR.
CAO.
CAAP.
CAAP's explain CAO's in simple (hmmm) language.
CAO's breakdown in greater detail the CAR's.
CAR's lay out the rules and practices that must be adhered to,
They are the Reg's, instrument if you will of the CIvil Aviation Act, which are the orders made by parliament.
Why would a CAAP be enforceable? It only exists to direct you to the act, which
Is enforcable.
I must be missing something here! (Ducks for cover!)

some interesting info,

http://www.ageingaircraft.com.au/files/2014_pres/CASA%20Ageing%20Aircraft%20Management%20Plan%20-%20Update.pdf

[Eddie Dean]

Thanks Perspective, that is a good reference:ok:

[LeadSled]

Perspective,

You are missing a few things:

The CAAct itself.
CASRs 1998,
Advisory Circulars
Between 4 and 5000 Legislative Instruments that vary the regulations.
Manuals of Standards, MOS, thousands of pages of them.
CASA Policy letters --- of very doubtful legal enforceability

etc, etc.

It would be an interesting and ultimately futile exercise to try and compile a definitive list, in order of precedence.

Australia's aviation regulations are a convoluted, complex and contradictory mess and getting worse by the day.

Tootle pip!!

[Eddie Dean]

A simple question about magneto overhauls segues to CASA are Cnts, way to go leadsled et al
Perhaps you all should start a thread about that.
Or maybe Aunty Pru would be more your style

Mi les Pinis

[tnuc]

CAR 50E Inconsistent requirements—resolution of inconsistencies
(1) This regulation applies where, apart from this regulation, a person would be required, by this Part, to comply with two requirements that are inconsistent

[Perspective]

Cleared,
The CAR will "allow" you to use CASA's list. Tick. CASA's list Sched. 5.
But, if you use Sched 5. Tick. Components must be covered.tick.
Per the approv. Data. Tick. Per MM. Per mfg CMM. As highlighted by SB
Which highlights the MM/CMM.

The Mag has to be done per MFG Data.
Don't focus on an SB that people argue is not mandatory.
If you want to focus on the SB disregarding all other references there is this.

Per the Reg's. CASA asks,
Does the manufacturer consider SB's optional.
From the Latest Piper manual.
"Piper considers SB/SL mandatory".

Quote:
"Australia's aviation regulations are a convoluted, complex and contradictory mess and getting worse by the day."

I would say it's actually going the other way, but by removing AD's that allow over run's for instance etc, probably not the direction people want!

[LeadSled]

A simple question about magneto overhauls segues to CASA are Cnts, way to go leadsled et al

Eddie,
Are you really suggesting that CASA and it predecessors are NOT the major reason for the state of the regulations.

Whatever you're smoking, it must be No.1 Good Sh1t.

I would say it's actually going the other way,

Would Part 61 (all 2200 pages and growing) be an example of "going the other way" ??
Or Part 173
Or Part 139
and so it goes on.

Tootle pip!!

PS: "Piper regards ----" but if they incorporate the SBs in the airframe manufacturer's MM, then it is required, just like Cessna SIDs. There are very good regulatory reasons why SB/SL (particularly when they are from component OEMs) are not automatically mandatory,( have not been incorporated in the airframe MMM) despite what the OEM might say, or what the airframe manufacturer might say, and Australian aviation regulation has never addressed this issue.

Hence, lots of heat, but not much light in this whole thread.

And still no takes as to why the C of A of your pride and joy may be invalid, or why you, as a LAME, might have signed a MR for an aircraft that does not have a valid C. of A.

[Perspective]

It least it's a nice day!
We better form a committee!
Are you suggesting there was a time SIDS wasn't mandatory?
It was only an AWB which "clarified" it after all.
Think I need a lay down....