CAR 232...an Ausfly experience coming to you? [Archive]

kaz3g

30th Aug 2015, 03:37

From Vocasupport:

Further damage to aviation accrues from CAR 232

A full 85 penalty points can accrue if an “operator” is ramp checked and has not:

(a) the flight check system has been approved by CASA;

(b) if CASA has required the system to be revised–the system has been revised in the manner specified by CASA.

85 penalty points at AUD$180 per point, so the maximum penalty is $15,300, making the administrative penalty $3060 – should improve the relationships with the aviation industry with #casa.

In the words of a long-time aviation member, there are serious issues here for all aviation participants:

“……By and large, what CASA micro-management will accept is a threat to air safety, the “approved systems” are so complex and extensive, and generally so contrary to manufacturer’s Airplane Flight Manual (AFM) recommended procedures, that they seriously impinge on the safe operation of the aircraft.

Note: That what is in the AFM, despite CAR 138, is not acceptable to at least two CASA regional offices.

Well, some bright spark in CASA has decided that, in the new Skidmore spirit of cooperation with industry, that CAR 232 should be rigorously enforced, after all it is “the law”, every aircraft has a “registered operator”, and CAR 232 rates a stand-alone mention in the CASA Ramp Check checklist, so it must be really, really important…..”

CIVIL AVIATION REGULATIONS 1988 – REG 232

Flight check system

(1) The operator of an aircraft shall establish a flight check system for each type of aircraft, setting out the procedure to be followed by the pilot in command and other flight crew members prior to and on take-off, in flight, on landing and in emergency situations.

Penalty: 25 penalty units.

(2) A flight check system shall be subject to the prior approval of CASA, and CASA may at any time require the system to be revised in such manner as CASA specifies.

(3) The pilot in command must ensure that the check lists of the procedures are carried in the aircraft and are located where they will be available instantly to the crew member concerned.

Penalty: 10 penalty units.

(4) The pilot in command shall ensure that the flight check system is carried out in detail.

Penalty: 25 penalty units.

(5) The operator of an aircraft must not allow the aircraft to be flown if the following requirements have not been satisfied:

(a) the flight check system has been approved by CASA;

(b) if CASA has required the system to be revised–the system has been revised in the manner specified by CASA.

Penalty: 25 penalty units.

(6) An offence against subregulation (1), (3), (4) or (5) is an offence of strict liability.

Note: For strict liability , see section 6.1 of the Criminal Code

Sunfish

30th Aug 2015, 04:24

I'm building experimental and there is NO AFM! I have a draft AFM provided by the manufacturer of the airframe with no responsibility "as is", no hard performance numbers besides VNE, VMO and an AUW and CG range. To that must be added the engine and propeller operators manuals and a Skyview manual.

Emergency procedures are generic for a single engined aircraft and specific for the engine and propeller. There are Two or three wrinkles to be added though. Even Rotax procedures depend to some extent on the configuration of the airframe.

If any of this has to be submitted to CASA for their perusal and analysis at my expense I'll quit building right now.

Typhoon650

30th Aug 2015, 04:37

Surely this is a joke or misinterpretation?

kaz3g

30th Aug 2015, 05:25

I have written to my federal Member, Sharman Stone about this and other regulatory disasters.

I also sent a copy to Sussan Ley, Health Minister, who flies her own C182 RG around her very large electorate and asked her if she would cop the fines.

My Auster has never had an AFM and operates on an exemption. I have a check list with my MR but it has never been authorised under 232 to my knowledge.

I wonder what the cost-recovery fee to approve will be. And I wonder how much it will cost to have an authorised and approved checklist prepared by a competent aero engineer?

Yes it's BS and the people doing ramp checks will probably be reined in with another exemption but the point is that it shouldn't happen!

Kaz

Duck Pilot

30th Aug 2015, 05:26

So we are no longer pilots, we are operators ???????

Clue, find out what CASA's definition of an "operator" is and all this will go away.

Lead Balloon

30th Aug 2015, 05:39

Doesn't matter what the definition of "operator" is for the purposes of CAR 232. Whatever it happens to be, CAR 232 still imposes obligations on pilots.

And if CARs 233 and 234 apply to all pilots including private pilots, CAR 232 does too.

That, presumably, explains why CASA's guidance on ramp checks says what it says about checklists.

Jabawocky

30th Aug 2015, 07:18

Sunny,

If any of this has to be submitted to CASA for their perusal and analysis at my expense I'll quit building right now.

Not sure if you are doing the Alphabet or telephone number rego option, but if its alphabet you will have a operation handbook or something like that put together, with check lists, the AP issues the CofA with that…. :ok:

LeadSled

30th Aug 2015, 07:42

Clue, find out what CASA's definition of an "operator" is and all this will go away. Duck Pilot,
That's an easy one (you could, of course, look it up) every Australian VH- aircraft has a registered operator, perhaps unsurprisingly it is part of the aircraft registration, and the registered operator is responsible for the operation of the aircraft.
Many moons ago there was Exemption EX38/2004 to CAR 232, but this can no longer be found on the CASA web site (by me, anyway) so it is a reasonable assumption that it has ceased to exist, and I can find no replacement.
If, in fact, this is the case, CAR 232 applies to all operations, and at least two CASA offices think this is the case.
Hence efforts to "nip in the bid" any attempts by CASA recalcitrant to spoil Ausfly, as they did Natfly for RAOz.
Tootle pip!!

Lead Balloon

30th Aug 2015, 08:04

There are numerous exemptions from 232 on the Federal Register of Legislative Instruments, but these all appear to be issued to individual operators.

There might be a 'general' one for private operations, but I couldn't find it.

But exemptions shouldn't be necessary or given, other than in extraordinarily unusual circumstances.

"Beyond a point, complexity is fraud."

thorn bird

30th Aug 2015, 08:05

Cost of getting CAsA approval for a "check" system???
So far around $2000 dollars for a completely unsafe concoction that the FOI imagines even comes close to operational reality.

Ultralights

30th Aug 2015, 08:21

so, what the regs are saying, is you need to carry, and use the aircraft checklists.. seams fair. shizer, even my cheap italian homebuilt has a decent checklist in the AFM. which i always carry on board, and use. cant be that hard. :E

Lead Balloon

30th Aug 2015, 08:32

Engine failure after take off.

Let's see, page .... page ... it will be behind the Emergency Procedures tab somewhere ... page .... dead ultralight!

It's a very simple question: Is rote learning checklists a system that has been approved by CASA and obviates the requirement to carry paper/electronic checklists?

LeadSled

30th Aug 2015, 08:46

No, Ultralite, sadly that is NOT what it say, I suggest you read CAR 232 as it is written, not as you think it is written.

The problem lies in the fact that CASA requires far more than the AFM checklist (whether they should or not is another legal argument, despite CAR 138) as a "flight check system", of which such "checklists" as CASA dictates will be part, and flight check system has to be approved for each and every operator.

Thus, if for example, there of 10 owners of a C-172 on your airfield, and each is the registered operator of his/her C-172, that is 10 separate flight check system must be approved by CASA.

This is what CASA do to AOC operators all the time, and it is almost "standard" that, if there are, say, two Kingair 200, with two different registered operators, the two CASA approved "flight check systems" will be very different, depending on the FOI. About all you can guarantee is they will be quite different to the manufacturer's recommendations, ie: the AFM.

For some years there was an exemption ( great regulation, write a regulation, then exempt about 80% of Australian aircraft) for most single engine aircraft and some others, in private operation, but that seems to have lapsed, at least in the belief of two CASA regional offices.

It is lunacy.

Tootle pip!!

Sunfish

30th Aug 2015, 08:53

Ultralights:

so, what the regs are saying, is you need to carry, and use the aircraft checklists.. seams fair. shizer, even my cheap italian homebuilt has a decent checklist in the AFM. which i always carry on board, and use. cant be that hard.

No Ultralights, CAR232 says you need checklists approved by CASA no matter who the author is.

I think I'll work on the veggie garden, and not the aircraft, until this is cleared up because I'll be ^&%^ed if I am going to be toyed with like this! How can an issue like this surface as "new" after Twenty ******* years of regulation reform??????? What ******* planet is CASA on????

Seriously, CASA seems to be bent on destroying all forms of aviation other than airlines and the military.

Ultralights

30th Aug 2015, 11:18

Seriously, CASA seems to be bent on destroying all forms of aviation other than airlines and the military

no, CASA has already destroyed almost all forms of aviation in Australia, bar, Military and airline.

on a little side note, interesting to see in todays press that senator for the greens being questioned on her multi million dollar travel expenses claims, all spent on chartering aircraft to regional towns not serviced by airlines... funny that.

back to CAR232, i have not had the time to read them yet, but will soon, do these effect homebuilt, Ie, experimental aircraft?

The name is Porter

30th Aug 2015, 12:57

Sunfish :cool: chill man, buy a bottle of cucumber gin on your way through Dubbo and relax, enjoy the airshow.

OZBUSDRIVER

30th Aug 2015, 13:28

Section 7 (https://www.casa.gov.au/sites/g/files/net351/f/_assets/main/manuals/regulate/aocm/220r007_vol2.pdf)of the AOC handbook has the exemptions.

Section 7.2 to be specific.

CASA EX38/2004 (https://www.comlaw.gov.au/Details/F2005B00505)

Is this the specific exemption?

If it is, suggest copying and laminating and placing in front of AFM.

Further to this and from the explanation section-
This exemption, therefore, exempts the operators of single and multi-engine piston engine aircraft not above 5700 kg maximum take-off weight and not involved in Regular Public Transport (RPT) operations, aircraft engaged in agricultural operations or private operations, single turbine engine helicopters certificated in the normal category and not involved in RPT operations or single turbine engine helicopters certificated in the restricted category not above 5700 kg maximum take-off weight or hot air balloons from the requirement to have the flight check system separately approved.

It also exempts all persons associated with the operation of the aircraft from the requirement, under subregulation 232 (5), not to fly the aircraft unless the flight check system has been approved.

As a condition on the exemption, an exempted operator will be required to describe the flight check system and publish it in the operator’s operations manual in accordance with regulation 215 or the aircraft’s flight manual.

OZBUSDRIVER

30th Aug 2015, 13:49

Seriously, why complicate the requirements...if an FOI pulls you up, point out the placards or the AFM and a copy of this exemption to make sure he/she/it understands that you are NOT a commercial OPERATOR nor RPT.

LeadSled

30th Aug 2015, 15:40

Oz,
Problem is, as far as can be determined so far, EX 38/2004 has been extinguished, it is no longer published on the Commonwealth Register of LIs. Although 38/2004 was not published with an expiry date, it seems to no longer legally exist, and, of course, the AOCM is only an advisory document.

Maybe 38/2004 was not exempt from the automatic sunset clauses of the Legislative Instrument Act 2003, although I can't see immediately why that would be.

We think this is what at least two CASA regional offices have realized, hence their newfound interest in going after private owners (operators) for non-compliance with CAR 232, which regulation is specifically mentioned in the newest Ramp Check checklist.

Ain't aviation in Australia wonderful??? So simple and straightforward, we are inundated with new people wanting to commit fun filled and fascinating flying.

Tootle pip!!

outlandishoutlanding

30th Aug 2015, 22:22

Problem is, as far as can be determined so far, EX 38/2004 has been extinguished, it is no longer published on the Commonwealth Register of LIs. Although 38/2004 was not published with an expiry date, it seems to no longer legally exist, and, of course, the AOCM is only an advisory document.

Maybe 38/2004 was not exempt from the automatic sunset clauses of the Legislative Instrument Act 2003, although I can't see immediately why that would be.

I still find it there; see on https://www.comlaw.gov.au/Browse/Results/ByTitle/LegislativeInstruments/Current/Ca/0

The sunset clause would keep it in place until 2020.

OZBUSDRIVER

30th Aug 2015, 22:25

To prove this situation-

Do a google search of any exemption you can think of. This will go to the AusLi site as the first or second hit. Open the link and check the details in the box in the upper right corner.

For argument sake. EX05/09 (https://www.comlaw.gov.au/Details/F2009L00073) This exemption has an expiry date of 2011. Look at the top right corner, it shows there the activity of the reg. Rescinded under the blanket instrument.

Methinks these FOIs are being too clever by half. Regretfully, how far do you have to go to prove these people do not know their job?

I'll keep at this for a bit longer to ensure my position.

EDIT to add...any exemption you open on the AusLi site will show on the left side of heading whether it is CURRENT, SUPERSCEDED or RESCINDED.

Lead Balloon

30th Aug 2015, 22:52

The only authoritative register is the Federal Register of Legislative Instruments. That ain't Austlii and it ain't the AOCM.

If you can't find the exemption on FRLI (or hidden somewhere in the regs), it isn't law.

The fact that there was a general exemption and reference in the AOCM to private operations shows that CASA considers 232 to apply generally. Why else would an exemption be required?

Mainframe

30th Aug 2015, 23:16

with regards to "Operator"

Duckpilot gave the clue, CAR 212 defines operator as the entity engaged in COMMERCIAL operations.

private owners engaged in private (non-commercial) operations are not the target of CAR 232.

relax and enjoy the show

OZBUSDRIVER

30th Aug 2015, 23:16

Lead Balloon...It IS there on the site....Do you want it written in blood, signed by the Director himself?

Further to your point-
Some (other) instruments of exemption are classified as legislative instruments, meaning they are routinely published on ComLaw in authoritative form. If an instrument of exemption is not on ComLaw, it may be available in the gazette or on request.

If there are FOIs running around with their own interpretations then best do something about it with the DAS at NRM. Copy of this thread, copy of exemption and any hearsay evidence that you may have of these two FOIs persecuting on their own interpretation of the law.

I hate unswarn officers who do not know their job...not as much as BS spreaders on this site!

thorn bird

30th Aug 2015, 23:19

"hence their newfound interest in going after private owners (operators) for non-compliance with CAR 232,"

Or could it be more about revenue raising?
I know of one operator who was charged 16 hours@$190 an hour for an FOI to check the manufacturer supplied, FAA approved QRH, exactly matched the Manufacturer supplied, FAA approved AFM.

The big problems occur when the procedure lists contained in the AFM built on 1970'ies philosophy and product liability are considered as checklists, leading to pages and pages of entirely dicretionary stuff like Air Conditioning.............AS REQUIRED,
without stating the obvious, if its bleeding hot turn it on, if it aint leave it off. This leads to forty fifty item taxi checklists with both pilots head in instead of head out which if anyone did a risk analysis it would perhaps indicate that this is not a real good idea as someone might happen to taxi into someone else, or worse enter a runway while an A380 is taking off because they are too busy checking stuff that has nothing to do with the safe operation of the aircraft.
In the end its all about liability, they really should take safety out of CAsA's title.

OZBUSDRIVER

30th Aug 2015, 23:33

If in doubt...RING FLIGHT OPERATIONS and ask them...I just did, the exemption is current and in force. If the FOI in question ramps you on this...Name and ID.

Have a nice weekend, people. Bloody BS abounds...Leadsled, you should know better!

Lead Balloon

30th Aug 2015, 23:34

Mainframe

CAR 212 starts with the magic words "in this Division":

"In this Division, operator means an operator engaging in commercial operations."

CAR 212 is in Divison 2. "This Division" is Division 2.

CAR 232 is in Division 3.

OZ: Please post the FRLI link to the exemption to which you refer. Some FOI saying it is so does not make it so.

And don't forget:

- CASA's published guidance on ramp checks for "GA pilots" says that you will be expected to provide paper or electronic copies of checklists,

- the reference in the guidance is to CAR 232, and

- CAR 232 requires the checklists to have come from a CASA-approved system.

OZBUSDRIVER

30th Aug 2015, 23:45

Already linked to the ComLaw site....The exact same site Flight Operations used to confirm this issue.

OZBUSDRIVER

30th Aug 2015, 23:47

LB, There are GA commercial operations...Where does it say GA PVT must also comply?

Lead Balloon

30th Aug 2015, 23:56

Where does it say GA PVT don't have to?

You must understand where this confusion originated. It originated from CASA guidance and the mess that is the regulations. It did not originate from anyone on pprune.

OZBUSDRIVER

31st Aug 2015, 00:19

kaz3g

31st Aug 2015, 00:50

I don't have an operations manual or an AFM...perhaps that means I don't have to bother about it

:rolleyes:

Kaz

Lead Balloon

31st Aug 2015, 00:54

So hopefully, if that exemption is still in force, someone in CASA will amend the CASA guidance on ramp checks so as to not cause further confusion.

Let's hope that, if it is in force, it isn't inadvertantly revoked.

And if the policy of the exemption is a good idea, one wonders why it could not have been enshrined in the regulations by now, more than a decade later.

"Beyond a point, complexity is fraud."

kaz3g

31st Aug 2015, 01:23

My information is direct from the Melbourne office of Flight Operations. This BS needs to stop! Ring them yourself! Bookmark the ComLaw site, download the PDF into your phone and have a hard copy, if you can, placed in the front of your Flight Manual.

GA PVT under 5700KG is exempt from CAR232 under EX38/2004!

The problem isn't so much whether the provisions of the CAR apply or whether there is an exemption, or who is defined as an operator, or even if there is an AFM to refer to; it's the source of the confusion.

Why is the CAR written in the negative instead of imposing a positive obligation? Why doesn't it use plain English? Why didn't it deal with the situation for aircraft under 5700 kg instead of another exemption of doubtful currency? What makes CASA a more learned authority than the worlds biggest manufacturer of GA SE aircraft or a small one for that matter? Why has all sense and reason flown out the window?

The answer is surely in the management, or lack thereof, commencing with successive Ministers and a long list of Directors whose experiences in the real world are limited or forgotten.

Write to your Members folks and keep telling them "no more!"

<first name.last [email protected]>

Kaz

Lead Balloon

31st Aug 2015, 01:54

Yep.

This issue is one example, out of many, that illustrates so vividly the pointless complexity of and confusion caused by the regulatory regime and the spectrum of learned helplessness across to outright rejection of the industry.

First there's the bunch of people who figure that CAR 232 doesn't apply to private ops. Ironically, they stumble into inadvertent compliance (actually, they inadvertently avoid non-compliance and criminality) because of an exemption that is over a decade old, if it is still in force. If it isn't in force, or is revoked, presumably this bunch of people will continue to operate safely, notwithstanding that they are in breach of CAR 232.

Then there's whoever drafted the guidance on ramp checks, who did not know about, or decided it wasn't worth mentioning, the existence of a general exemption from CAR 232, and instead stated categorically that GA pilots would be expected to provide evidence of written or electronic checklists, with a reference to CAR 232 and, by implication, all the requirements of CAR 232. (So what if people read CASA guidance as meaning what it says? That's their problem!) The alternative is that whoever drafted the guidance on ramp checks believes that the exemption is no longer in force.

But let's be thankful to our benign regulator if there is an exemption in force that exempts private ops generally from compliance with CAR 232. And let's be thankful to our benign regulator for choosing, each day, not to revoke the exemption.

And let's hope that at some point in their busy days and somewhere on their list of priorities for regulatory reform over the next few decades, our benign regulator can manage to arrange for an amendment to the regulations so that the exemption isn't required in the first place.

I reckon we should have a whip around the industry to raise a couple of million or so, to fund the insertion of a couple of words into CAR 232. A big, stressful job for CASA, I know. But with enough time and money and the industry's support, CASA just might be able to arrange it.

"Beyond a point, complexity is fraud."

Frank Arouet

31st Aug 2015, 02:25

CAsA have emphatically refused to entertain any amendments to any regulations that mirror the FAA stated "foster or encourage or promote" and by doing so they affirm the industry vote of no confidence, (as stated in The Forsyth Review), by them doing the exact opposite.
It could be this matter is intentional if not incompetent. They can't have it both ways.

oldrotorhead

31st Aug 2015, 03:54

I followed my nose using a Google Search and eventually ended up here -https://www.comlaw.gov.au/Details/F2005B00505
which very clearly shows this exemption as being Current.
Cheers,
ORH

LeadSled

31st Aug 2015, 04:43

Folks,
I think we have established that EX 38/2004 is still current, but, curiously, you will not find it going the ComLaw via the CASA web site that ostensibly has links to all such matters.

However, this still leaves the matter of the "footnote" on the bottom of 38/2004, which almost negates the rest of the exemption, especially if you are an FOI with evil intent.

So, what I don't know is whether some smarty in CASA thought the 38/2004 was extinguished, or whether they thought they were going to hang their hat on the "footnote".

Either way, there has been enough on the subject of CAR 232, including direct representation to CASA to ensure the "top floor" is aware, and to hope that there will be no interference with Ausfly.

I certainly hope so, after what was done to Natfly.

Tootle pip!!

PS: This is yet another prime example of how difficult it is to know what "the aviation law" actually is, in Australia.

Recently, an AOC application was knocked back by CASA. As part of the preparation, the "applicant" went back through five (5) years of AsA HO NOTAMS. It transpired that the knock-back was because there were HO NOTAMS even older, "the applicant" was "deemed" to not have complied with CASA AOC application conditions.

Lead Balloon

31st Aug 2015, 23:27

Having looked at all the posts and relevant materials, I realise that I should apologise for my scaremongering.

As anyone with any experience in the aviation regulatory regime in Australia knows, any guidance produced by CASA is almost invariably inaccurate and misleading.

I should have realised that CASA's guidance on ramp checks does not mean what it says. Despite the heading and content, CASA won't be asking GA PVT pilots for paper or electronic checklists from a check system approved by CASA. The CASA inspectors will know, just by looking, or will accept the pilot's assertion, that the operation is PVT, and will know about an exemption that's not mentioned in the guidance.

I should have realised that the answer to what the requirements are can almost never be answered by looking at the rules: the exemptions are the main regulatory game in Australia.

I should be thankful that the lawfulness of my PVT operations depends on an exemption, granted and revoked at the whim of the regulator.

I should have realised that all the rhetoric about outcomes-based regulations under which exemptions will not be required is just that: empty rhetoric. I should have realised that 28 years is nowhere near enough time to incorporate changes into CAR 232 - which was in the original 1988 regulations - to negate the need for yet another exemption and to make the narrow application of the check system requirements clear on the face of the rules.

Most importantly, I should have realised that almost almost everybody is so confused by the complexity that they just do their best to operate safely, and don't need more distraction and confusion from scaremongers pointing at the five different provisions and documents that you have to read to work out to whom CAR 232 applies and what CASA hopefully intended to say in its guidance.

And as anyone with any experience knows, the guidance will quietly be changed, without any version reference or record, and all of this will never have happened.

My apologies. Now, back to Stockholm and my well-learnt helplessness. :ok:

kaz3g

1st Sep 2015, 05:40

Note that the exemption, if still in force, only applies to sub regs (2) and (5) so you must have a comprehensive checklist and use it...no memory stuff...use the checklist.

When the noise stops at 500'...get the checklist out and use it or cop a fine.

And be careful of that tricky wording in Schedule 2...

Kaz

Lead Balloon

1st Sep 2015, 07:04

Stop scaremongering, kaz!

People don't want to know that even if the exemption is in force, all of this still applies to PVT GA aircraft: 232 Flight check system

(1) The operator of an aircraft shall establish a flight check system for each type of aircraft, setting out the procedure to be followed by the pilot in command and other flight crew members prior to and on take‑off, in flight, on landing and in emergency situations.

Penalty: 25 penalty units.

(2) [exemption applies]

(3) The pilot in command must ensure that the check lists of the procedures are carried in the aircraft and are located where they will be available instantly to the crew member concerned.

Penalty: 10 penalty units.

(4) The pilot in command shall ensure that the flight check system is carried out in detail.

Penalty: 25 penalty units.

(5) [exemption applies]

(6) An offence against subregulation (1), (3), (4) or (5) is an offence of strict liability.

Note: For strict liability, see section 6.1 of the Criminal Code.

People don't want to know that the CASA guidance on ramp checks is therefore accurate. Pilots of PVT GA aircraft can be asked to produce paper or electronic copies of the checklist of the procedures from the flight check system established by the operator, and those pilots risk being considered in breach of 232(3) if those copies can't be produced. And if the pilot can't produce the copies, s/he is going to have difficulty in explaining how s/he can comply with 232(4).

But relax: The CASA guidance on ramp checks and CAR 232 read in light of the exemption don't mean what they say.

IFEZ

1st Sep 2015, 07:27

Far out. I'm developing a headache. If we need this much debate over something as simple as whether we should be carrying a checklist, no wonder we're all lost on the rest of it. When I did my training, up to PPL you didn't need a written checklist, doing it from memory was ok. As soon as I started doing my CPL training, we were required to use a written checklist. Back then it seemed simple. PVT = no checklist. Commercial = checklist. Am I simplifying it too much..? Was I taught wrong..?:confused:

Lead Balloon

1st Sep 2015, 07:42

I suppose it depends on whether rote learned checklists count as being "carried in the aircraft" and "located where they will be available instantly to" the PVT pilot. If the pilot's head is in the aircraft, and the pilot's head contains the checklists established by the operator and the pilot can recall them instantly, I don't see why that shouldn't be enough.

I suppose we'll find out CASA's opinion on the question, the next time they ramp check a PVT flight and ask for written or electronic copies of checklists in accordance with ramp check guidance, and the pilot says: "It's all in my head!"

27/09

1st Sep 2015, 08:15

kaz3g

1st Sep 2015, 08:40

(3) The pilot in command must ensure that the check lists of the procedures are carried in the aircraft and are located where they will be available instantly to the crew member concerned.

Penalty: 10 penalty units.

"INSTANTLY"....Who wrote this this stuff? How does anyone comply with "instantly"? Why would they?

Kaz

Cloud Basher

1st Sep 2015, 08:45

Agreed, except for "Is it CASA approved?"

Of course it is. By virtue of having passed CAsA exams and being issued a licence; ergo we are approved!

End of story.:ugh::ugh::ugh:

Cheers
CB

djpil

1st Sep 2015, 08:51

Exactly Kaz! I stow all documents when doing aerobatics.

Talking with Colmar Brunton (for CASA's Safety Promotion communication research) so will include this topic.

OZBUSDRIVER

1st Sep 2015, 10:13

This exemption, therefore, exempts the operators of single and multi-engine piston engine aircraft not above 5700 kg maximum take-off weight and not involved in Regular Public Transport (RPT) operations, aircraft engaged in agricultural operations or private operations, single turbine engine helicopters certificated in the normal category and not involved in RPT operations or single turbine engine helicopters certificated in the restricted category not above 5700 kg maximum take-off weight or hot air balloons from the requirement to have the flight check system separately approved.

It also exempts all persons associated with the operation of the aircraft from the requirement, under subregulation 232 (5), not to fly the aircraft unless the flight check system has been approved.

As a condition on the exemption, an exempted operator will be required to describe the flight check system and publish it in the operator’s operations manual in accordance with regulation 215 or the aircraft’s flight manual.

Even I should read this more carefully. This exemption covers everyone NOT flying RPT

not involved in Regular Public Transport (RPT) operations

Exempts aircraft not RPT! That means EVERYTHING ELSE UNDER 5700kg.

???Makes you feel real important challenge responding away to yourself in your complex C182. This issue highlights how piss poor our flight training regime has become. Admittedly, until this thread surfaced I did not know we all operated light aircraft under a blanket exemption...from a law written to capture RPT.....but now I know and I am armed with that knowledge.

thorn bird

1st Sep 2015, 11:18

"As a condition on the exemption, an exempted operator will be required to describe the flight check system and publish it in the operator’s operations manual in accordance with regulation 215 or the aircraft’s flight manual."

Oz, does this mean everyone must have some sort of "Check System" in their Flight Manual??

As I read it, Catch 22 if your ramped..."May we see your flight manual"
Ah Ha!!..."Where is your flight check system"??

YES!! Your nicked you damned criminal, YES!! got another one!!
20 thousand penalty points, cough up you damned criminal!!

Duck Pilot

1st Sep 2015, 12:28

For god sake people, this is a storm in a tea cup.

I will be there, ask me 😀😀😀😀😀

Sunfish

1st Sep 2015, 20:17

Ducky, there are a Thousand other tea cups! That is the problem.

Taken individually, yes. It's a storm in a tea cup. But isn't it the case that virtually every other regulation has similar exemptions attached to it? This is why we are drowning! There is no point in studying the regulations; they prohibit everything not covered by plain vanilla Qantas RPT.

The problem we have here is structural - whole swathes of the Aviation industry for example RAA and Experimental, exist only by virtue of exemptions!

Then there are the emerging technologies - UAV's, ADS -B, EFB's advanced EFIS, traffic information systems. etc. etc. The benefits of which cannot be harvested by Australian aviators without exemptions.

"So what" You say? The problem, Ducky, is that the use of exemptions by the regulator maximises risk to the regulated because, by definition, the making of an exemption is at the pleasure of the regulator. This is because an exemption is not yours by right, subject to natural justice, procedural fairness and the entire set of Weberian bureaucratic procedural rules. Furthermore, the exemption can be revoked just as easily as it is created.

And what does the heightened level of risk mean for the regulated? Why it means jobs, investment and growth Ducky. Do I need to talk about risk premiums and rates of returns? The use of exemptions in Australia means that any aviation investment in what in other jurisdictions would be risk free is fraught with risk in Australia because it has to rely on exemptions to be operated let alone earn a sufficient return. Just ask Dick Smith. Ask the bloke who wanted to operate single pilot light jets.

In my case I have spent some $60,000 and invested hours of my time to try and build something which may fly only by virtue of exemptions. That doesn't worry me too much because I needed the therapy of just building it. If it all gets too hard to jump through more hoops, I will simply chainsaw the structure and sell the motor and avionics or shove the whole thing in a container and give it away to some African missionaries.

However think about the opportunity costs for the entire industry - how many investments are NOT made simply because the potential investor gets one whiff of how CASA is going to regulate him and just walks away? That is why our "storm in a teacup" matters.

Lead Balloon

1st Sep 2015, 21:40

Even I should read this more carefully.Why bother, Oz?

Surely all you need to do is shout: THE EXEMPTION EXISTS.

:rolleyes:

OZBUSDRIVER

1st Sep 2015, 22:55

Thorn bird, as someone pointed out a page ago.

To date, I have completed three special feature endorsments, I have passed my PPL and have had three AFRs...in all those assessments I have used a rote checklist. The aircraft I fly has a factory issued flight manual as well as a quick reference checklist...the manual is here...indicate...the quick ref check list is here...indicate. This is what you would say if you are DESCRIBING what you do and how your aircraft is equipped.

I have not studied the requirements for a kit built aircraft, I would understand there would have to be something on paper from the manufacturer as to the limitations placed on the aircraft by factory testing and design...same as section IV in all manuals. I would guess that anyone who builds their own aircraft would be creating a manual from derived data. The rote checklist would still stand.

OZBUSDRIVER

1st Sep 2015, 23:09

Appols on the shouting bit. A protocol I still have issues with, to be sure. Wasn't shouting but certainly trying to highlight the important bits.

Lead Balloon

1st Sep 2015, 23:45

You did lead with your chin...

Anyway, for all of this complexity, we still don't know the answer to a simple question: Does CASA consider that rote-learned checklists, alone, can satisfy the requirements of CAR 232, to the extent that those requirements apply to PVT GA pilots?

We know that CAR 232 applies universally. It's just that the exemption exempts certain aircraft operators and their pilots from some (but not all) bits of CAR 232.

We also know that CASA's guidance on ramp checks for GA pilots says that CASA will ask for written or electronic checklists, with no distinction between GA PVT and GA AWK/Charter etc.

So going by all that, you'd be forgiven for believing that CASA doesn't consider rote-learned checklists to be sufficient.

It would be so easy for CASA to make a statement clarifying its approach, one way or the other.

I have absolute confidence in Jabba's integrity and I have no doubt that he's had a word in the ear of someone important who's made some representations about what CASA will and won't do at AusFly. But is that the proper way to give industry confidence about the regulator's approach?

OZBUSDRIVER

2nd Sep 2015, 00:22

Lead Balloon...I am in fierce agreement!

I see this all the time in other pastimes. I used to enjoy drag racing bigbore motorcycles....regretfully, so did a lot of outlaw motorcycle gangs. Many times I attended all bike meets that had big populations of gang members. It was only in Victoria that we were met with huge police presence to actively "discourage" participation by racers as well as spectators (cash source). Liberal interpretations on what described a road worthy vehicle. Best interpretation was...your spare tyre is not the same brand as your fitted tyres rewarded with a canary! Total BS!...but do you argue with a member of the Task Force?

...the guy with the tyres? He was the land owner! The task force defected the water truck which, effectively, cut off all the ablution blocks...public health? They tried everything to shut the show down...we never put on another one.

I see parallels in the actions of FOIs only at big gatherings of aircraft. Safety or discourage? I hope the SAAA has every and continued success with NRM. If allowed to develop, this could and will become our version of Osh!

kaz3g

2nd Sep 2015, 05:32

As a condition on the exemption, an exempted operator will be required to describe the flight check system and publish it in the operator’s operations manual in accordance with regulation 215 or the aircraft’s flight manual.

Even I should read this more carefully. This exemption covers everyone NOT flying RPT

As mentioned earlier, I don't have an AFM because my Auster never had one and is "exempt".

So does my AFM exemption exempt me from complying with the condition in the CAR 232 exemption or should this situation be better categorised as an "exception" to avoid confusion?

Kaz

djpil

2nd Sep 2015, 05:52

The flight manual for my airplane is a document controlled by the manufacturer and approved by the FAA; I have no authority to publish a change to it.

My recollection of CASA's view of Auster's etc without an AFM is that the placards provide sufficient information.

LeadSled

2nd Sep 2015, 05:53

kaz3g,
And you probably don't have an Operations Manual either (because they are not required for private operation), in which to "affix" the document(s) required by the footnote.

Remember, an AFM in not an Operations Manual.
Remember, a "flight check system" is not just a checklist.

Another example of a rather silly "one size fits all" rule to assist CASA micromanagement of aviation, and then not even being able to write an exemption that is clear and unambiguous, and actually applies to those operation that CASA seeks to exempt from a rule that shouldn't be in the first place.

But we all know we are not supposed to know and understand, because aviation law "is for lawyers and judges, for the safe conviction of pilots and engineers".
Tootle pip!!

Lead Balloon

2nd Sep 2015, 07:56

On my reading of the exemption, the conditions apply only to commercial operations. But if that were intended, it could have been a stated a lot more clearly.

no_one

2nd Sep 2015, 08:11

...and this is why we all love aviation in Australia. You need to be a talented linguist and a sharp lawyer to even agree that you are allowed to commit aviation.

I wonder if on the Professional Lawyers Rumour Network they have an aviation section?

andrewr

2nd Sep 2015, 10:15

A new piece of paperwork out of CASA that has the potential to cause some headaches: AWB 51-008.

(Extracts)

Effectivity
All aircraft that utilise tubular steel structure that is or forms part of the primary (or secondary) structure of the aircraft

Aircraft operators should ensure that the maintenance program for an aircraft constructed from welded tubular steel structure includes a requirement to periodically inspect all external and internal surfaces of the tubular structure. Any approved maintenance program which does not include a periodic inspection that will detect corrosion in the structure may be considered inadequate

(Emphasis mine)

If an appropriate inspection technique or NDT procedure is not available in the existing approved data for the applicable aircraft, such data may need to be developed by an NDT specialist in conjunction with a CASR 21M Delegate.

I wonder whether an engine mount is a primary or secondary structure? I would have thought so. Do aircraft have inspection techniques or NDT procedures in existing approved data that will detect corrosion on the internal surfaces of the engine mount?

Not to mention the effect on the presumably intended targets, where the fuselage etc. is welded steel tube.

How much weight does a "recommendation" in a AWB carry?

OZBUSDRIVER

2nd Sep 2015, 11:36

A story (https://www.casa.gov.au/standard-page/fsa-issue-95-internal-corruption-0) behind the AWB

andrewr

2nd Sep 2015, 12:00

Yes I understand the problem.

However I wonder whether it was necessary to declare potentially most/all current approved maintenance programs inadequate, and whether NDT procedures really need to be developed for each aircraft by a NDT specialist and CASR 21M Delegate.

andrewr

2nd Sep 2015, 12:08

Interesting... the one I was referring to is Issue 2. Issue 1 seems more reasonable.

Issue 1:

CASA recommends that if engineers or aircraft owners are concerned about
and / or suspect possible internal corrosion on tubular structures to consult with a specialised NDT person

Issue 2:

Aircraft operators should ensure that the maintenance program for an
aircraft constructed from welded tubular steel structure includes a
requirement to periodically inspect all external and internal surfaces of the
tubular structure. Any approved maintenance program which does not
include a periodic inspection that will detect corrosion in the structure may
be considered inadequate

OZBUSDRIVER

2nd Sep 2015, 20:37

"Periodic" is concerning....once every fifty years? Not!

To be sure, I am not familiar with the full suite of CARs for maintenance. There would have to be some sort of trigger to progress to NDT using X Ray examination. The case in question would indicate...corrosive environment, drains blocked or open to atmosphere, integrity of structure indicates weaken of joints..rather than a calendar date in service.

Sunfish

2nd Sep 2015, 20:52

This will morph into X-ray inspection of engine mounts every Two years.

Lead Balloon

2nd Sep 2015, 23:29

How much weight does a "recommendation" in a AWB carry?Just like the first blowie reminding us that summer is on the way, an AWB is a signal of an impending AD.

The dead giveaway is the buzzing in the background getting louder: you noted the difference in language between Issue 1 and Issue 2.

This is what happened with stainless steel terminated cables. The AWB morphed into an AD. Having demonstrated how well industry has learned to be helpless - the cable AD was met with little more than a shrug of resignation from the industry - CASA is moving on to primary and secondary tubular steel structures.

andrewr

3rd Sep 2015, 08:57

To be sure, I am not familiar with the full suite of CARs for maintenance. There would have to be some sort of trigger to progress to NDT using X Ray examination.

The way I read it, if there is not something already in the approved data for the particular aircraft, the operator is expected to pay a NDT specialist and CASR 21M Delegate to develop a program of periodic inspections.

Presumably they would set the intervals for inspection.

My gut feeling is CASA bit off more than they intended here. I doubt it was intended to include all aircraft, but I can't really see that you could claim the engine mount was a less important structure than e.g. the tail spring mount.

Sunfish

3rd Sep 2015, 09:05

My response would be to buy a new engine mount

andrewr

3rd Sep 2015, 10:00

That doesn't solve the problem of an "inadequate" maintenance program.

Sunfish

3rd Sep 2015, 10:28

CASA is incapable of building an "adequate" maintenance program. Comprehensive? Expensive? Both yes. "Adequate"? No.

For me, an internal wash with epoxy primer is adequate, coupled with a design that is fail safe or now " damage tolerant" so that blind Freddy can see he has a problem before bits fall off.

To put that another way; remind me how many corrosion related catastrophic failures of welded tubular structures have we had compared with all the other sources of accidents?

Jabawocky

3rd Sep 2015, 13:47

Sunny, all those tubular structures were clearly inadequate …..in 100% of fatal accidents the tubular segments all failed. They must be dangerous!!! :}

LeadSled

3rd Sep 2015, 14:09

Jaba,
Careful, you might give some of the militants in CASA ideas.

Seriously, in this day and age, there are better things than linseed oil to fill tubes after welding. Having had some experience in such things, I would not go for a hard coating, but any one of a number of the coatings that are both a mechanical barrier to moisture, and have anti-corrosion properties.

Tootle pip!!

yr right

3rd Sep 2015, 19:29

. Having had some experience in such things, I would not go for a hard coating, but any one of a number of the coatings that are both a mechanical barrier to moisture, and have anti-corrosion properties.

Omg. You are God. Knowledge of all. Master of all you must be god.

This is something I know a lot about. Even had this point in Court brought up.

How funny. Is there anything you don't know leadie.

Tootle pip!![/QUOTE]

Frank Arouet

3rd Sep 2015, 23:42

yr write;

Are you stalking LeadSled?

yr right

4th Sep 2015, 00:16

yr write;

Are you stalking LeadSled?

nope not at all. He is very entertaining don't you think. I think he should head Casa be the PM and how about state prem as well. Head Easa may be FAA and maybe NZ Caa as well. Head the the law department and may be write the exams for aircraft maintenance. He could run a course on LOP and how to fill out a M/R as well.

But no I'm not.

LeadSled

4th Sep 2015, 09:43

How funny. Is there anything you don't know leadie. Yr' wrong,
Why don't you tell us all what is, engineering wise, incorrect in my last post.
Fact is, you think you know about my background and experience, but by your posts, continually illustrate you have no idea.
Tootle pip!!

He could run a course on LOP and how to fill out a M/R as well.
PS: As it happens, been there, done that.

yr right

4th Sep 2015, 09:52

Yr' wrong,
Why don't you tell us all what is, engineering wise, incorrect in my last post.
Fact is, you think you know about my background and experience, but by your posts, continually illustrate you have no idea.
Tootle pip!!

PS: As it happens, been there, done that.

Quite frankly your arse is jealous of what comes out of your mouth.

Your statement on linseed oil for a start. Do you know why that is used. So how many m/r have you issued oh that's right zero nil nada but your an expert on that. And btw I know lots about yourself. People only to happy to talk about your self. Blah blah.

So please tell us how you cam manufacture a window and install it. Still not done that.

LeadSled

4th Sep 2015, 10:08

Your statement on linseed oil for a start. Do you know why that is used.

yr' wrong,
Go back to the ATSB report on a previous post on this thread.
I stand by my statement that, in this day and age, corrosion prevention in tube frames has come a long way since linseed oil.
Tootle pip!!

PS: Has it ever occurred to your tiny mind that 4130 tube frames are not limited to aircraft, I built my first one before I was old enough to vote.

yr right

4th Sep 2015, 10:17

yr' wrong,
Go back to the ATSB report on a previous post on this thread.
I stand by my statement that, in this day and age, corrosion prevention in tube frames has come a long way since linseed oil.
Tootle pip!!

PS: Has it ever occurred to your tiny mind that 4130 tube frames are not limited to aircraft, I built my first one before I was old enough to vote.

Wow 4130 not just for aircraft I'll be. Well I was first introduced to 4130 myself at approx 10 ish myself with race cars as well. Please also read my previous post where I was a whiteness in court against Casa o. This very subject. So yea I know a lot about it. And the way it was worded is all but directly what I said in court.

LeadSled

4th Sep 2015, 12:40

LeadSled

4th Sep 2015, 12:51

where I was a whiteness in court against Casa o. This very subject. So yea I know a lot about it

Yr' wrong,
Maybe I should claim my first teething ring was 4360, or better still, EN 60.

You whitness ?? as opposed to a blackness??

Actually, the fact that you gave testimony on a particular matter in court means ??

So yea I know a lot about it ---- does not follow, although you presumably knew enough for the purposes of your testimony as a tradesman, but even this could only be determined by reading the transcript, particularly any cross examination.

Tootle pip!!

yr right

4th Sep 2015, 21:06

So please tell us how you cam manufacture a window and install it. Still not done that.
Yr' wrong,
I have already pointed you to the relevant regulations and associated advisory material, if you can't read and understand them, it is not my problem. That it is apparently beyond your present level of knowledge is not relevant, as to whether or not it can be done.

Tell us dumb ones/ Show us exactly where its say you may manufacture parts.

Folks,
This is a bit of an addendum to my last post, I think it is highly likely that Mr. yr' wrong has only a very limited knowledge of paint systems developments over the years, with particular application to corrosion control.

In correct more than likely more up to date than what you are.

Linseed oil treatment of welded tube structures was probably the pointy end of such techniques in 1915, but it is now 2015. Indeed, the various proponents, after about 100 years, still can't agree on whether it should be raw or boiled linseed oil.

Once again you have not shown why it is used. Ill give you a clue it has more than one use

After all, as I understand it, Mr. yr' wrong is what the FAA call a maintenance technician or mechanic, although in Australia we dress it up with the term "engineer", which, in most countries would mean holding at least a BE, not just a trade qualification.

Once again incorrect. An Aust LAME carrys out more than what a FAA IA can do and considerately more than an AMP

Such a person would not be expected to have an in-depth knowledge of such specialist matters, but rather a functional knowledge sufficient to carry out basic aircraft maintenance instructions and tasks relevant to his trade.

Once again LAME is not a trade.

So lets look at it this way;
I have never seen anyone that has not been able to fly. If you can drive a car you can fly, Only one person had real trouble she moved training centres and got though it.

Now kid of the street with 12 months training into a 4 engine bomber over Germany getting the sh&t shot out of him at night in bad weather. In a little over 12 months of training.

Now different kid goes into engineering.
1st year can find his shoes
2 nd can do his laces up
3 getting some where
4 not to bad
5,6,7,8 learning really started
9,10 I can with reasonable confidence place him onto the hangar floor and not have to check on him ever five minutes.
Now when he is doing his lic (which was the hardest in the world to achieve ) when I started 3 sittings a year, now still only 10. No walk in and sit down at a computer at basically when you wish.

So lets look at that again 1 year to 10 years, No wonder a former PM called you BUS drivers.

The difference between a Dr and an engineer is a Dr place there mistakes into the ground, and only do it one at a time.
Some post back you said you often have trouble with engineers. We can see why.

As such, he would not be expected to have an in-depth knowledge of such operational matter as LOP engine operations, which are not maintenance tasks, although, it would seem likely he believes he is an authority on such matters. Quite why this seems to be so is not clear.

Once again incorrect. We as LAME know and have to know all aspects of aviation with the exception to nav when you do engine airframe but EIR know more about it than any pilot would ever know.
Difference is you pay to do a course then you pay for us to fix your mistakes after you done the course its a win win.

Likewise, Mr. yr' wrong does does not seem to understand that there is no requirement to be an AME or LAME to carry out instruction on how to correctly fill out a maintenance release. I can assure Mr. Yr' wrong that at all relevant time I was suitable qualified and licensed to carry out such aviation instruction.

In CORRECT once again.
What about the AA exam our did we forget about that.You know AA its the exam on AIr Law for engineering , woops I forgot you have not done that exam have you.
Please state your qualification's to this statement. On a previous post you admitted you haven't issued a M/R. so what the go. Yep lots of typos on M,R, why because a generally rule end of the day pilot waiting to go and typos are made. So please other than typos what mistakes do we make.

In fact, on far to many occasions I have found new M/Rs releasing an aircraft to service have not been correctly completed by the signatory on the release.

Such as

Tootle pip!!

Now anyone that's knows me also knows I get on extremely well with pilots so please do not think for one minute that im down on you guys. I also will never give you an aircraft that I would not fly in myself. But when people get on this site and make statements that they know it all and clearly do not, as has been pointed out by others as well. Statements like LOP for example, I see the damage I answer there questions and will not be drawn into this again. Make a new thread. I and others like my self need and have to know all aspects of aircraft applications, this not only means what we do in the hangar but what and how it is used why it is used and operational aspect's in flight. To that point I had a problem in flight wit an aircraft. The owner said they went through this problem over the week end and came up with what they thought was the proplem. I got all the info for the flight profile and found and said what the problem was. They said know because xyz still works , yep because of this. Changed component done. And anyway we all know what this person is about and how he acts even with his own kind.
http://www.pprune.org/images/statusicon/user_offline.gif http://www.pprune.org/images/buttons/report.gif (http://www.pprune.org/report.php?p=9105393)

OZBUSDRIVER

4th Sep 2015, 21:40

yr right

4th Sep 2015, 21:49

Yr right...in truth your level of education is just about associate diploma mech engineering level...wish I knew that thirty years ago, would have sat all the exams in one hit.

However, this is getting away from the real issue...FOIs making up their own interpretations in the field. Anyone been pineappled on any other issues?

I've heard of one guy that wanted a dual insp on a ballon knots for the vents. Washing an aircraft and not putting it on the M/R. Ask Aora what they done to him. Some one said early that we not the police but yet we made to be. It's getting worse than ever. You all need to be careful.

yr right

4th Sep 2015, 21:58

Yr' wrong,
Maybe I should claim my first teething ring was 4360, or better still, EN 60.

You whitness ?? as opposed to a blackness??

Actually, the fact that you gave testimony on a particular matter in court means ??

So yea I know a lot about it ---- does not follow, although you presumably knew enough for the purposes of your testimony as a tradesman, but even this could only be determined by reading the transcript, particularly any cross examination.

Tootle pip!!

Luckily you weren't around when Noah was building his boat hey.

Lead Balloon

4th Sep 2015, 22:10

Occasionally someone in CASA reincarnates the myth that there's a 6 POB limit on PVT ops and costs must always be shared equally among the POB in order for ops to be PVT.

According to whoever the numpty is/are, a provision that deems an operation with particular characteristics to be one kind of PVT operation actually defines the only operation that can be PVT. :ugh:

LeadSled

5th Sep 2015, 00:07

Yr right...in truth your level of education is just about associate diploma mech engineering levelOZ,
Under the AQF (or whatever it is called now) maybe, maybe not. Speaking from having sat on the peak body setting up the "competency based" system some years ago.

Washing an aircraft and not putting it on the M/RActually, putting it on the MR and then washing the aircraft to manufacturer's MM, came from CASA lectures at a traveling roadshow. It was also effectively included on a CASA CD about Schedule 8 maintenance.

Once again LAME is not a trade.
yr' wrong,
That is not what I said, but I'll let that go, you seem to have trouble with English comprehension.
I'll bite, if you are not a tradesman, what are you?? What classification do you think you fit into.
Do you believe you are qualified to be a member of the Institute of Engineers, and can therefor call yourself a professional engineer.

As a general statement, in my opinion you are one of the most prejudiced persons I have ever seen on pprue, with an attitude, not common but not rare among LAMEs, a belief in a level of aviation knowledge that borders on fantasy (witness your claims that you know all about aircraft operations, except nav.), allied with the firm belief that all pilots are dumb idiots.

Even on the subject of "linseed oil" it is clear to me that you only have a limited knowledge, certainly not the "big picture". That's OK for what you have to do, you don't need to know the in depth why, just the how, any more than a painter has to know about paint chemistry.

Of course, what would I know of the US/NZ/UK etc. systems, I am just a dumb pilot who only hold CPL/ATPL whatever in a variety of countries.

Tootle pip!!

baron_beeza

5th Sep 2015, 00:51

I don't know if we actually see many LAME comment on pilot or nav matters on most forums. From what I am seeing I am guessing many pilots seem to think that they may have knowledge on aircraft maintenance matters.

This has carried over from the transparencies thread but I made a comment there that the rules can't easily be read in isolation.
I can think of one example straight off that may resonate with a few here.
I was working in one country many years ago when they went through a rule revamp.
Anyway it had the expected clause about ground running and taxiing aircraft by non-pilots. No-where did it say that LAME's could not actually fly the aircraft though. As we know if you understand the aircraft inside out and can taxi and do ground runs etc then flying is easy after that.

I know myself and several other engineers had a very good understanding of the rules, if perhaps a little selective.
Anyway we noticed that if the engineering staff flew on the aircraft immediately prior to the maintenance check we could detect minor defects that may have been overlooked otherwise. Door noise and other similar rattles etc comes to mind.

Anyway eventually I started flying the aircraft and could then pick up on such things such as throttle cable notchiness in the cruise, or having to resync the pitch. The pilots enjoyed the new feel of the machines so much that I did a deal with one whereby I flew his last flight of the day. It was after my work in the hangar anyway and I could then tackle any abnormalities straight away the following day.
We were often carrying fare paying passengers but I never did tell them that I was the engineer.
Why would I and as was stated on the other thread there was no harm done.

I know the other engineers were doing exactly the same with other companies. I am sure the reasoning was the same, many defects were getting rectified that would otherwise be missed. That has to be a good thing and as I said no-where in the rules did it say that we couldn't.
It is just a matter of which eye you have to close when you read, right ?

For all that, flying an aircraft is a little over-rated. There is nothing that difficult about it.

Frank Arouet

5th Sep 2015, 01:25

Two pilot LAME's come to mind and both refused to fly my aircraft after annual inspection. I always thought this was an indication of their faith in the work. Having said that I'm reminded of some historical statistics regarding the most dangerous times for aircraft mechanical breakage is straight after someone having worked on it. This morphed into unnecessary inspections dictated by regulatory authority. Someone will correct me I'm sure, but I think there was a military study done also. Perhaps they were just looking after their insurance risks and passing that task to the owner/ now test pilot. I believe this is called "problem transference".

yr write: My dealings with LAME's has not been pleasant in that they generally charge outrageously, refuse to accept responsibility, lock your aircraft up if there is a dispute, sometimes do inspections by mail, tell fibs and believe they are God.

This Deity however being claimed by a recently departed CAsA AVMED Director which would make LAME's "tradespersons" which in turn mandates they use the tradesman's entrance at my house. I hope this doesn't offend because it shouldn't if you know your place.

OZBUSDRIVER

5th Sep 2015, 01:38

Leadsled, my opinion is based on studying Assoc. Dip.Mech Eng at the old QIT. Fast forward to current and trying to help my son pass the old system LAME exams. The course notes for engines and basic exam covered some (not all) of my engineering course. Engines was a good course, answered a lot of questions regarding the inards of big radials that I was always afraid to ask...cam timing, good subject:ok: Passed that easily, same with props.

....hence the statement. I would describe LAME as a technical trade, nothing more.

Eyrie

5th Sep 2015, 03:01

I've often wondered why the Institute of Engineers hasn't taken action to prevent LAMEs using the title "engineer".

baron_beeza

5th Sep 2015, 05:55

And pilot is a profession ?

LeadSled

5th Sep 2015, 09:24

And pilot is a profession ?

Baron B.,
I think the answer to that is probably not.

I am reminded of the situation, many tears ago, of an application to the old Industrial Relations Commission by the then Australian Airline Pilots Association to be removed from the basic wage system, and be "recognized" as a profession.

The application failed and the Commission decided that an airline pilot was the equivalent of a First Class Fitter, plus a margin for skills.

Profession/Professional is, in my view, now a very debased term, when I hear hairdressers describing themselves as "professionals", as if merely getting paid for something makes you a professional. Indeed, in my view, many younger pilots are quite precious about this aspect of their job.

-my opinion is based on studying Assoc. Dip.Mech Eng at the old QIT.

Oz, I think I agree with you, I have a rather outdated engineering qual., which falls somewhere between Ass. Diploma and Diploma of Engineering, Mechanical, the comment that I would make it that there was a lot more theoretical design content in thencourses, than I see in present similar courses. It was/is the equivalent of years one and two of the then engineering degree, which was then three years for a BE.

Tootle pip!!

Trent 972

5th Sep 2015, 09:36

Ahem, you plonkers are like school kids fighting over play lunch.
Why don't you take your bullsh!tting over to the APRuNe (Amateur Pilots Rumour Network).:ok:

kaz3g

5th Sep 2015, 10:54

So how is Ausfly?

Don't forget pancake brekky and flyin at Shepp on the way back.

Kaz

j3pipercub

5th Sep 2015, 12:17

Is it just me, or does anyone else think Leadsled and yr right are actually really really attracted to eachother?

j3

dubbleyew eight

5th Sep 2015, 13:28

I've replaced my windscreen 3 times now.
I buy the sheet, cut it to shape, drill it and install it myself.
I've replaced the side windows.

stupid, stupid rules bound idiots most of you.

linseed oil ?
the product is called tubeseal. you can get it from polyfiber or aviaquip in tullamarine. it works a treat.

is it something in the water or are you guys all taking stupid pills lately.

to hell with this :mad: I have some more TIG welding to do that is far more interesting.

LeadSled

5th Sep 2015, 16:56

Is it just me, or does anyone else think Leadsled and yr right are actually really really attracted to eachother?

J3,
You jest, of course.
As far as I am concerned, in my opinion one of the things that has done so much damage to aviation in Australia (not the only thing, of course) is the attitude and misinformation from people like yr'wrong.

linseed oil ? the product is called tubeseal

Quite, as I said in an earlier post, we have had some developments since 1915 --- but immediately disputed by yr' wrong with much invective, after all, what would a dumb and dopey pilot know.

Tootle pip!!

baron_beeza

5th Sep 2015, 19:45

A keen motorbike owner is nearing the end of a 3 year restoration on his classic machine. He goes onto a forum discussion to ask about the costs involved in getting the compliance, inspection and tax done. VIN, WoF and rego.

Someone replies with..
'Put a false plate (from another bike) on it and just ride. The number of miles is negligible as it is only a hobby bike. The chances of an accident are slim as you will be riding carefully on the expensively restored bike.
As a bonus if you do get caught then the fine will probably be less than what all the other costs are going to come to over the years anyway. It saves a lot of drama and may be cheaper.'

I am sure there must be people about that feel the original question has been answered...

Fortunately for us, pilots have more sense.

Frank Arouet

6th Sep 2015, 01:29

Linseed oil is for cricket bat's. What else do you want to know?

LeadSled

6th Sep 2015, 02:33

So is a medical DR a trade because its not a true Doctorateyr'wrong,
You really have a problem, don't you.

A medical practitioner is a professional by qualification, usually starting of with an MB/BS or equivalent degree, which is not obtained by a combination of trade school and apprenticeship, by whatever name. The title Dr. for a physician( or dentist) is really a title justified by common usage, but many (particularly English) surgeons just go by the title Mr.

For your information, the mandate for competency based training and standards is not limited to aviation, it applies to all fields of education in Australia.

The present shambolic situation with AME licensing in Australia is not as a result of competency based standards, but is entirely CASA self generated.

The Australian LAME license was never the hardest to get ( although Australia was and is always pretty good at singing its own xenophobic praises), one of the overseas objections to recognising Australian licenses in recent years has been because of the limited training required (in teaching time and scope) in Australia, compared to most of Europe, SE Asia or the US, and the resultant limited knowledge and experience.

As for the rest, I have already answered, but obviously not to your satisfaction, I am afraid you will have to settle for my answers, once your prejudices are settled, mere facts will not disturb them. Some of your rather crude scatological phraseology does you no credit.

You really should get out more, it might puncture some of your self delusion.

Tootle pip!!

Mach E Avelli

6th Sep 2015, 06:06

Children, children; the adults on this site won't show you 'respect' while you keep waving your willies at each other. Your short attention span pisses some of us off too. Sadly, beatings are no longer allowed - apparently kids go on medication these days.
Back to the OP's concerns about CAR 232 etc. Yes, we should be concerned about all the penalty points and the whole punitive approach to something relatively unimportant in the grand scheme. Whatever happened to consultation, counselling and education, with enforcement only as a last resort? There are only a few pilots who would not respond to a firm but reasoned bollocking if a ramp check showed that they lacked required documentation.
However, despite the Draconian wording of CAR 232, it has been my experience with checklists in G.A. that CASA would not know what they have or have not approved. Even at airline level, while there will be a record of it somewhere, if it is more than a few years old it is most likely on the operator's books, not CASA's.
I have seen plenty of checklists - both home-made and official manufacturers' - but I have never, ever, seen one with "CASA CAR 232 approval ...dated......" stamped on it. The more official-looking ones usually have the operator's amendment date. Maybe put a date on your home made one then. Old enough to have been lost in the CASA archives, but not so old that it pre-dates the POH or AFM checklist. And all the better if the content is the same as the POH or AFM because then YOU have a reference that CASA won't have on the spot, and would be unlikely to challenge. Whether you really use it or not is another thing, but in a single pilot operation how would the FOI conducting the ramp check actually know?
There is a long list of 'stuff' they can ping you on during a ramp check, but as far as I can see, any checklist - whether it be a whole book, a laminated card or OEM placards on the panel (way to go!) - is likely to satisfy the inspector on the day. In an RPT operation a diligent FOI could conceivably reference the operator's manual suite, but in GA? Which office is the inspector from? Which office does the oversight on your aircraft? If they are doing dozens of ramp checks, bothering about such trivia would be too time consuming. If they are in prosecute-mode, there will be easier findings to bring in the revenue.
So............ woe betide you if your charts are not up to date, and/or you are overloaded, because they CAN check those against their references or bathroom scales.

Lead Balloon

6th Sep 2015, 07:27

Mach: This thread is not about whether there should be a return to some mythical good ol' days of "firm but reasoned bollocking" rather than a "punitive approach".

It's primarily about a very simple question: Can the operator of an aircraft and its pilot engaged in PVT operations satisfy the requirements of CAR 232, as 'modified' by the exemption, by establishing and implementing a system of rote-learned emergency and normal checklists?

There can only be one answer out of two mutually exclusive alternatives. The answer is either 'yes' or 'no'.

If the answer is yes, there is no ground on which an FOI can deliver a "firm but reasoned bollicking", or anything else, to a PVT pilot who does not produce paper or electronic copies of checklists, in accordance with the CASA guidance on ramp checks for GA pilots. If the answer is yes and the pilot says s/he's rote-learned the checklists for the aircraft, presumably the FOI can ask: "What are your actions if you suffer an engine failure after take off?", and the pilot can choose whether to answer or not.

If the answer is no, CASA should make a clear statement that it requires copies of paper or electronic checklists to be produced by GA pilots during ramp checks, irrespective of the classification of the operation.

Then there's the overarching issue of complexity ...

"Beyond a point, complexity is fraud."

Mach E Avelli

6th Sep 2015, 08:31

If only we could return to the days when we rote learned basic checklists!
My take on CAR 232 is that any pilot unable to produce a checklist in some physical form would bring down the wrath of CASA, I think CAR 232 is fairly explicit on that, so to keep the peace I always have a checklist accessible. Can't be bothered with the cost of challenging it by not having at least something to show the person from government who is here to help.....

In my little Sonex I made a checklist that simply says Fuel, Flap, Trim, Controls & Canopy and stuck it to the panel. Do I really need such a complex checklist? Probably not, but it is there just in case the workload gets to be too much for my senile brain.
Did CASA 'approve' it? No, and unless they offer a free service to do same, will not be invited to. Are they required to approve checklists for private operations? Dunno, but seeing as the aircraft is RA AUS registered, it's an interesting grey area. Like much of the legislation, CAR 232 seems to be applicable to all aircraft, regardless of rego. It is ridiculous and fraudulent complexity indeed.

Who was it said " rules are for the guidance of wise men and the blind obedience of fools " ?