LAME Imposter.
Join Date: Mar 2007
Location: Sydney
Posts: 137
Likes: 0
Received 0 Likes
on
0 Posts
Splashman,
You raise two separate points within your questions, namely am I licensed and do I understand the MEL system.
No I am not a licenced AME, and of course no I haven’t certified as such.
Do I understand the MEL system, well probably better than you think although I am not privy to the QF MEL.
The MEL forms part of the CASA approved System of Maintenance for a Class A aircraft, it is not mandatory to have an MEL but it offers an immediate Permissible Unserviceability system without further need for delegate approval under CAR37.
An Australian MEL is a derivative of the country of origin MMEL and is considerate of local requirements for which the aircraft will operate under, typical examples being:
- Radio requirements to suit Australia, HF etc
- Emergency egress equipment based upon your CASA evacuation demonstration and how many cabin crew carried etc (one slide out with reduced passenger load and door placarding etc)
- Any Australian AD requirements that are applicable to the aircraft and its defined role
The MEL is applicable to the aircraft and the certificate of registration holder and is not transferable, as mentioned earlier it forms part of the CASA approved System of Maintenance and will be listed on the equivalent of page 1 of the CASA approved Aircraft Log Book.
Now back to your example.
There are a couple of considerations in the scenario that you offer.
In applying the MEL the engineer must consider the current status of the aircraft, not just the defect for which he/she is presented. If the (M) conditions of the MEL can be met then the engineer is permitted to apply the MEL upon completion of the maintenance actions required and once satisfied that no other condition inhibits the application (already having a deferred defect or other inappropriate aircraft condition etc).
Once the engineer has applied the MEL the PIC must ensure that they can meet the (O) conditions for the intended flight. Acceptance of the MEL is discretional for the PIC who must consider all of the circumstances of the intended flight including weather, suitability of alternates etc. Once the PIC has a valid Maintenance Release and a certified application of an MEL then he is permitted to fly within the limitations of the MEL until expiry.
Which brings me to your point, the MEL has expired, can the aircraft fly.
Unless there is further relief available within the MEL Preamble then the MEL expires after the stated period in the applicable MEL item. At this point the Maintenance Release ceases to remain valid and the aircraft is not permitted to fly unless some other PUS or Special Flight Permit is issued under the provisions of the CAR’s.
If the aircraft did fly with an expired MEL then the following would be questioned:
- How and why did the PIC accept an MEL that was expired?
- Why did the CASA approved maintenance control procedures not detect the expiry and prevent further flight?
- If a Maintenance Release had been issued after the MEL expiry, why did the person issuing the MR not detect the expired MEL?
I trust that this answers your questions……… now let me ask you one…..
You are the engineer responsible for final certification and coordination for an aircraft that has undergone a major modification. The mod has been performed under a foreign STC and whilst part way through the modification it was found that a part didn’t fit correctly. A CAR35 approval was granted for the local manufacture and installation of a different part and also a CAR 36A approval was granted for some alternate fasteners (not an uncommon situation).
In reviewing the work that has been completed and just prior to you making the final certification you are asked…
1. At the completion of the modification and upon issue of the Maintenance Release, who is held responsible for ensuring that the aircraft has continued to meet its type design, and how is that assured?
2. Who is held responsible for ensuring that the ongoing airworthiness instructions relative to the modification have been incorporated into the approved data for the aircraft?
Over to you…….
MP.
You raise two separate points within your questions, namely am I licensed and do I understand the MEL system.
No I am not a licenced AME, and of course no I haven’t certified as such.
Do I understand the MEL system, well probably better than you think although I am not privy to the QF MEL.
The MEL forms part of the CASA approved System of Maintenance for a Class A aircraft, it is not mandatory to have an MEL but it offers an immediate Permissible Unserviceability system without further need for delegate approval under CAR37.
An Australian MEL is a derivative of the country of origin MMEL and is considerate of local requirements for which the aircraft will operate under, typical examples being:
- Radio requirements to suit Australia, HF etc
- Emergency egress equipment based upon your CASA evacuation demonstration and how many cabin crew carried etc (one slide out with reduced passenger load and door placarding etc)
- Any Australian AD requirements that are applicable to the aircraft and its defined role
The MEL is applicable to the aircraft and the certificate of registration holder and is not transferable, as mentioned earlier it forms part of the CASA approved System of Maintenance and will be listed on the equivalent of page 1 of the CASA approved Aircraft Log Book.
Now back to your example.
There are a couple of considerations in the scenario that you offer.
In applying the MEL the engineer must consider the current status of the aircraft, not just the defect for which he/she is presented. If the (M) conditions of the MEL can be met then the engineer is permitted to apply the MEL upon completion of the maintenance actions required and once satisfied that no other condition inhibits the application (already having a deferred defect or other inappropriate aircraft condition etc).
Once the engineer has applied the MEL the PIC must ensure that they can meet the (O) conditions for the intended flight. Acceptance of the MEL is discretional for the PIC who must consider all of the circumstances of the intended flight including weather, suitability of alternates etc. Once the PIC has a valid Maintenance Release and a certified application of an MEL then he is permitted to fly within the limitations of the MEL until expiry.
Which brings me to your point, the MEL has expired, can the aircraft fly.
Unless there is further relief available within the MEL Preamble then the MEL expires after the stated period in the applicable MEL item. At this point the Maintenance Release ceases to remain valid and the aircraft is not permitted to fly unless some other PUS or Special Flight Permit is issued under the provisions of the CAR’s.
If the aircraft did fly with an expired MEL then the following would be questioned:
- How and why did the PIC accept an MEL that was expired?
- Why did the CASA approved maintenance control procedures not detect the expiry and prevent further flight?
- If a Maintenance Release had been issued after the MEL expiry, why did the person issuing the MR not detect the expired MEL?
I trust that this answers your questions……… now let me ask you one…..
You are the engineer responsible for final certification and coordination for an aircraft that has undergone a major modification. The mod has been performed under a foreign STC and whilst part way through the modification it was found that a part didn’t fit correctly. A CAR35 approval was granted for the local manufacture and installation of a different part and also a CAR 36A approval was granted for some alternate fasteners (not an uncommon situation).
In reviewing the work that has been completed and just prior to you making the final certification you are asked…
1. At the completion of the modification and upon issue of the Maintenance Release, who is held responsible for ensuring that the aircraft has continued to meet its type design, and how is that assured?
2. Who is held responsible for ensuring that the ongoing airworthiness instructions relative to the modification have been incorporated into the approved data for the aircraft?
Over to you…….
MP.
MP, all you've done is read what CASA says, you have obviously never worked in the engineering department of an airline at all......... you still haven't answered the original question............How can the aircraft fly if it doesn't meet the MEL?
You still don't understand the relationship between the CAR's and the airline do you?
Here's another question. Does the Captain have to accept an aircraft with a failed item that's within the MEL?
Does the Captain have to accept an aircraft with anything he thinks is sub standard even if its not even referred to in the MEL?
And another question, have you ever heard the expression: "The light came on just after we took off", what does it mean?
At this point the Maintenance Release ceases to remain valid and the aircraft is not permitted to fly unless some other PUS or Special Flight Permit is issued under the provisions of the CAR’s.
Here's another question. Does the Captain have to accept an aircraft with a failed item that's within the MEL?
Does the Captain have to accept an aircraft with anything he thinks is sub standard even if its not even referred to in the MEL?
And another question, have you ever heard the expression: "The light came on just after we took off", what does it mean?
Join Date: Mar 2007
Location: Sydney
Posts: 137
Likes: 0
Received 0 Likes
on
0 Posts
OK Sunfish,
I was asked and I answered.
Tell me then where you would find what I wrote in CASA documentation or explanatory notes. You will note from my previous posts that wherever that has been available I have quoted the reference for all to benefit.
So come on, find what I wrote......... spend a couple of weeks trying.... I am a patient man.
If you do find something then maybe I should charge them royalties...
MP.
I was asked and I answered.
Tell me then where you would find what I wrote in CASA documentation or explanatory notes. You will note from my previous posts that wherever that has been available I have quoted the reference for all to benefit.
So come on, find what I wrote......... spend a couple of weeks trying.... I am a patient man.
If you do find something then maybe I should charge them royalties...
MP.
Join Date: Mar 2002
Location: Oz
Posts: 381
Likes: 0
Received 0 Likes
on
0 Posts
Ahh ... it's not THAT simple.
The PIC must have an overwhelming reason to reject a permissible unserviceability. That is, when they say no when presented the logbook ... pass them the phone, Duty Captain on the other end of the line. Short conversation later and he will be back in his l/h seat.
Many moons ago, some Qf captains took great delight in not accepting defects covered by the MEL. APU inop .. I'm not going .. yes, of course Captain.
Airlines stand to lose alot of doe when planes are grounded. If she's airworthy, she flies.
The PIC must have an overwhelming reason to reject a permissible unserviceability. That is, when they say no when presented the logbook ... pass them the phone, Duty Captain on the other end of the line. Short conversation later and he will be back in his l/h seat.
Many moons ago, some Qf captains took great delight in not accepting defects covered by the MEL. APU inop .. I'm not going .. yes, of course Captain.
Airlines stand to lose alot of doe when planes are grounded. If she's airworthy, she flies.
Many moons ago, some Qf captains took great delight in not accepting defects covered by the MEL. APU inop .. I'm not going .. yes, of course Captain.
Join Date: Dec 2006
Location: WZRCHS
Posts: 51
Likes: 0
Received 0 Likes
on
0 Posts
MP
Your answers to my questions are legally correct..well done.
Without research, I would initally say that a foreign STC cannot be altered.
If a CAR 36 approved person changes a foreign STC, then LAME should not accept the changes.
If a PIC does not accept an MEL then so be it, legally he/she can, however in the real word, someone else will fy the aircraft and the next months roser for the said PIC?????????????
I would be the first to stand corrected, however this area is out of my domain...Give me a bit of time to research; as I gave you
My problem with your posts are that they do not apply to the real world.
You implied, that QF LAME thinks that they can work outside of the CAR's.
They do all the time.
Examples
The fact that a standby compass can be deemed unserviceable, by virtue of CASA limits, then found internally acceptable (compass swings cost money).
Maintenance by telephone,
How many flights take off after discussion between the PIC and QF Maint watch, no tech log entry, no LAME sign off. What happens if something goes amiss, believe me the maint watch LAME is only responsible for a sign off, yes he could be held responsible for advice given, but very hard to prove.
PIC not happy with MEL
In todays world it is quick chat with the Duty Chief pilot.
In my 11 years with QF, never has the PIC, said, no way I do not agree and I am not flying the aircraft. Should he/she ever do, I guess they will get someone else to fly. And next months roster for the PIC??????????????
Engine boroscope damage found out of limits, but deemed OK (internally, within the company), OK to fly with pax !!!!!!!!
At a remote outstaion, your mobile rings, you answer, and find you are a part of a conference call, the CAR 35/36 holder says " cannot let that go" and you have to say I never asked you to, I did not ring you.
5 examples of internal pressures/stress being thrown at flight crew and engineers. You would think they have never heard of Human Factors yet they teach it to their LAME's .
QF lames do not have to comply with the CAR;s, when they are varied by approved persons, who most likely are empoyed by QF.
Let me know how I did with your question, its not a bitch fight, but I would never pass an opinion on something I know nothing about, you seem to.
Splash
Your answers to my questions are legally correct..well done.
Without research, I would initally say that a foreign STC cannot be altered.
If a CAR 36 approved person changes a foreign STC, then LAME should not accept the changes.
If a PIC does not accept an MEL then so be it, legally he/she can, however in the real word, someone else will fy the aircraft and the next months roser for the said PIC?????????????
I would be the first to stand corrected, however this area is out of my domain...Give me a bit of time to research; as I gave you
My problem with your posts are that they do not apply to the real world.
You implied, that QF LAME thinks that they can work outside of the CAR's.
They do all the time.
Examples
The fact that a standby compass can be deemed unserviceable, by virtue of CASA limits, then found internally acceptable (compass swings cost money).
Maintenance by telephone,
How many flights take off after discussion between the PIC and QF Maint watch, no tech log entry, no LAME sign off. What happens if something goes amiss, believe me the maint watch LAME is only responsible for a sign off, yes he could be held responsible for advice given, but very hard to prove.
PIC not happy with MEL
In todays world it is quick chat with the Duty Chief pilot.
In my 11 years with QF, never has the PIC, said, no way I do not agree and I am not flying the aircraft. Should he/she ever do, I guess they will get someone else to fly. And next months roster for the PIC??????????????
Engine boroscope damage found out of limits, but deemed OK (internally, within the company), OK to fly with pax !!!!!!!!
At a remote outstaion, your mobile rings, you answer, and find you are a part of a conference call, the CAR 35/36 holder says " cannot let that go" and you have to say I never asked you to, I did not ring you.
5 examples of internal pressures/stress being thrown at flight crew and engineers. You would think they have never heard of Human Factors yet they teach it to their LAME's .
QF lames do not have to comply with the CAR;s, when they are varied by approved persons, who most likely are empoyed by QF.
Let me know how I did with your question, its not a bitch fight, but I would never pass an opinion on something I know nothing about, you seem to.
Splash
Seems to me you need to submit a REPCON report to the ATSB. CASA are to close to QF to give you the time of day. Whilst the ATSB have protocols with how they investigate your report (they ask CASA to investigate and report back to ATSB), they are probably the only ones who are showing any interest at the moment to the situations you have found yourself in. Go to the ATSB website for instructions on how to fill one in and submit.
Thread Starter
Join Date: Mar 2005
Location: n.s.w
Posts: 189
Likes: 0
Received 0 Likes
on
0 Posts
A lot of people have a lot to say in this thread, and everyone is correct to a degree. I may as well throw my 2 cents worth in and wait to be shot down as well.
Can a plane fly with an expired MEL? Not unless there is relief granted by an approved person. Whilst that person may be employed by the airline they are approved by CASA and have been given the authority to do so.
Can a PIC reject an MEL? Certainly they can, but extreme pressure will be placed on them to accept it and most normally do.
Who is reponsible if something goes wrong, the LAME, the approved person or the PIC? In my oppinion it has to be the approved person otherwise we wouldn't need them, as we would only be be working to the limits set by the manufacturer.
In relation to the Maintenance Release, this was changed a while ago so that it remains valid for a set period of time, usually 12 to 18 months and is revalidated at a major check, C or D or unless a major defect has occurred usually structural damage then the MR ceases to be valid. This is in the QF system I don't know if other airlines followed suit.
The RTS (Return to Service) needs to be validated for each flight.( I know there are variations to this. )
In a perfect world no aircraft would fly with defects outside the limits of the MM, SRM or MEL, however it is not perfect and most airlines around the world operate with defects outside the limits with approval from their governing body, FAA, EASA or CASA otherwise no aircraft would be flying and we'd all be out of a job.
Aircraft have flown with expired MEL's, MR's and RTS's due to oversights by engineers and flight crew not intentionally.
By the way this thread has gone off on quite a large tangent from the origonal LAME Imposter, maybe we should get back on track or start a new one dealing with CASA regs and maintenance issues.
Will sit back and wait for the attack.
Can a plane fly with an expired MEL? Not unless there is relief granted by an approved person. Whilst that person may be employed by the airline they are approved by CASA and have been given the authority to do so.
Can a PIC reject an MEL? Certainly they can, but extreme pressure will be placed on them to accept it and most normally do.
Who is reponsible if something goes wrong, the LAME, the approved person or the PIC? In my oppinion it has to be the approved person otherwise we wouldn't need them, as we would only be be working to the limits set by the manufacturer.
In relation to the Maintenance Release, this was changed a while ago so that it remains valid for a set period of time, usually 12 to 18 months and is revalidated at a major check, C or D or unless a major defect has occurred usually structural damage then the MR ceases to be valid. This is in the QF system I don't know if other airlines followed suit.
The RTS (Return to Service) needs to be validated for each flight.( I know there are variations to this. )
In a perfect world no aircraft would fly with defects outside the limits of the MM, SRM or MEL, however it is not perfect and most airlines around the world operate with defects outside the limits with approval from their governing body, FAA, EASA or CASA otherwise no aircraft would be flying and we'd all be out of a job.
Aircraft have flown with expired MEL's, MR's and RTS's due to oversights by engineers and flight crew not intentionally.
By the way this thread has gone off on quite a large tangent from the origonal LAME Imposter, maybe we should get back on track or start a new one dealing with CASA regs and maintenance issues.
Will sit back and wait for the attack.
