Qantas Maintenance Changes
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Why don't you RTF-thread name buddy, last time I looked we weren't operating light twins...
At the end of the day, if you are a QF pilot you can't open engine panels. Get over it and get over yourself.
At the end of the day, if you are a QF pilot you can't open engine panels. Get over it and get over yourself.
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checking with CASA
SRM,
So, that was the DAS was it? Hopefully not just an AWI, given the pages of PPRuNe filled with criticism of CASA's lack of standardisation and policy control...
Yes, the Act does define maintenance for the purposes of those sections that it seeks to specifically regulate, such as s20AB:
As an aside, the existence of s20AB is why your waving around of s24 as the "crime" is wrong.
As to the general thought that CASA would use s20AB(2) to stitch up an unauthorised change of light bulb or, shock horror, opening a quick access panel - highly unlikely, given the need to establish beyond reasonable doubt a fault and a physical element as well as the need to explain to the beak why you are wasting his/her time on matter more appropriately dealt with under the regulations and the administrative fines system.
Because the Act does not seek to regulate servicing, it is not defined therein. However, the regulations are intended to deal with the myriad of lesser crimes that do not invoke the spectre of incarceration for offending - guess what we find:
So then we come to the distinction between inspection and "checking" as raised by Aeromedic - I suspect it would take a serious court to determine whether a task such as checking a fluid level, albeit one of many tasks constituting a maintenance inspection such as a daily inspection, is of itself automatically defined as maintenance.
It seems reasonable that an inspection is a search for defects. However, it also seems reasonable that a diminished fluid level is not a defect, although an excessive usage rate may well be. Is the identification of a need for servicing due to a diminished fluid level reasonably defined as maintenance and, if so, is it legally defensible to demand an authorisation to identify a need for an activity for which an authorisation is not required to conduct?
Now back to the matter that is really at hand.
If a company decides that it will not allow certain groups of people to conduct certain activities, then that is entirely an internal matter. If such a restriction results in inefficiencies and entrenches work practices that are otherwise not required, that remains a matter of commercial choice. However, if that company then elects to change that established "custom and practice", then they are equally committed to manage the change to ensure that safety is not compromised.
Finding "crimes" in the legislation is not the solution - identifying the shift in risk from LAME to pilot and assessing the consequential change in overall risk is the first step in developing the mitigators, followed closely by the risk recipient determining if the mitigators are sufficient for them to accept the expansion of their personal risk exposure.
And this is where CASA fails - change management in this case is not solely the prerogative of the company and it is not solely about theoretical processes, it is all about "where the rubber hits the road" and it must be assured by the regulator at the risk recipient level!
The solution comes from the representative bodies holding a blow torch to CASA's feet to ensure that a mutually satisfactory outcome is achieved, since CASA lacks the intellectual and practical horsepower to unilaterally assure a safe outcome.
I have checked with CASA...
Yes, the Act does define maintenance for the purposes of those sections that it seeks to specifically regulate, such as s20AB:
20AB Flying aircraft without licence etc.
(1) ...
(2) A person must not carry out maintenance on:
(a) an Australian aircraft; or
(b) an aeronautical product in Australian territory; or
(c) an aeronautical product for an Australian aircraft;
if the person is not permitted by or under the regulations to carry out that maintenance.
Penalty: Imprisonment for 2 years.
(1) ...
(2) A person must not carry out maintenance on:
(a) an Australian aircraft; or
(b) an aeronautical product in Australian territory; or
(c) an aeronautical product for an Australian aircraft;
if the person is not permitted by or under the regulations to carry out that maintenance.
Penalty: Imprisonment for 2 years.
As to the general thought that CASA would use s20AB(2) to stitch up an unauthorised change of light bulb or, shock horror, opening a quick access panel - highly unlikely, given the need to establish beyond reasonable doubt a fault and a physical element as well as the need to explain to the beak why you are wasting his/her time on matter more appropriately dealt with under the regulations and the administrative fines system.
Because the Act does not seek to regulate servicing, it is not defined therein. However, the regulations are intended to deal with the myriad of lesser crimes that do not invoke the spectre of incarceration for offending - guess what we find:
servicing, in relation to an aircraft, means preparing the aircraft for flight, and includes providing the aircraft with fuel and other fluids that are necessary for its operation, but does not include any work that is maintenance.
It seems reasonable that an inspection is a search for defects. However, it also seems reasonable that a diminished fluid level is not a defect, although an excessive usage rate may well be. Is the identification of a need for servicing due to a diminished fluid level reasonably defined as maintenance and, if so, is it legally defensible to demand an authorisation to identify a need for an activity for which an authorisation is not required to conduct?
Now back to the matter that is really at hand.
If a company decides that it will not allow certain groups of people to conduct certain activities, then that is entirely an internal matter. If such a restriction results in inefficiencies and entrenches work practices that are otherwise not required, that remains a matter of commercial choice. However, if that company then elects to change that established "custom and practice", then they are equally committed to manage the change to ensure that safety is not compromised.
Finding "crimes" in the legislation is not the solution - identifying the shift in risk from LAME to pilot and assessing the consequential change in overall risk is the first step in developing the mitigators, followed closely by the risk recipient determining if the mitigators are sufficient for them to accept the expansion of their personal risk exposure.
And this is where CASA fails - change management in this case is not solely the prerogative of the company and it is not solely about theoretical processes, it is all about "where the rubber hits the road" and it must be assured by the regulator at the risk recipient level!
The solution comes from the representative bodies holding a blow torch to CASA's feet to ensure that a mutually satisfactory outcome is achieved, since CASA lacks the intellectual and practical horsepower to unilaterally assure a safe outcome.
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(How is inspection defined? When I do an external preflight it is to verify the airworthiness of the aircraft. Doubly so when no engineer performs the task. So I check for gear pins, brake wear pins, tyre condition, external damage, missing static wicks, leaks, etc, and I check the fluid quantities, various temps and pressures on my gauges. On the 737 pilots even check hydraulic reservoir sight glasses.)
The pilot preflight is NOT a maintenance inspection and therefore, is not part of the aircraft's Approved Maintenance Program (AMP).
Not my words.
servicing, in relation to an aircraft, means preparing the aircraft for flight, and includes providing the aircraft with fuel and other fluids that are necessary for its operation, but does not include any work that is maintenance.
This means refuelling, toilet and potable water servicing.
The pilot preflight is NOT a maintenance inspection and therefore, is not part of the aircraft's Approved Maintenance Program (AMP).
Not my words.
servicing, in relation to an aircraft, means preparing the aircraft for flight, and includes providing the aircraft with fuel and other fluids that are necessary for its operation, but does not include any work that is maintenance.
This means refuelling, toilet and potable water servicing.
Last edited by SRM; 25th Apr 2014 at 09:58.
Cool Banana...where did I express a yearning to get my hands dirty? I asked a simple question related to the thread. Don't bother replying.
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Here is the CASA published list of servicing tasks:
Servicing Tasks
Refuelling and de-fuelling;
Fuel system water drain checks;
Replenishment of hydraulic fluid;
Replenishment of engine oil;
Toilet cleaning;
Replenishment of engine coolant;
Replenishment of water;
Sanitize potable water;
Adjustment of tyre pressures;
Replenishment of de-icing fluid;
Periodic lubrication of components, other than lubrication that is required for the accomplishment of scheduled maintenance, which does not require disassembly of the component, other than removal of non-structural items such as cover plates, cowlings and fairings eg: lubrication of door hinges;
Aircraft internal and external cleaning, including windscreen cleaning;
Disinfecting of the aircraft;
Removal of ice and snow;
Application of preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good maintenance practices;
Checking aircraft battery electrolyte levels and topping up with distilled water but excluding wet cell nickel-cadmium batteries;
Servicing tasks required by the aircraft flight manual or maintenance manual;
Towing, parking and mooring including tasks to facilitate these functions eg: quick disconnect and re-connection of torque links; and
Replacement or repair of signs and markings.
Note: The servicing of liquid and gaseous oxygen systems is to be carried out only by an appropriately rated LAME.
As mentioned earlier, if any of these are written into the aircraft Approved Maintenance Program (not a policy or procedure manual) then they are maintenance tasks.
Further factual reading here:
Civil Aviation Safety Authority - AWB 12-1 Issue 2 - Aircraft servicing and ground handling tasks
Again, that's not to say that any of this is appropriate for any particular operator. But these are the actual regulator guidelines.
MP.
Servicing Tasks
Refuelling and de-fuelling;
Fuel system water drain checks;
Replenishment of hydraulic fluid;
Replenishment of engine oil;
Toilet cleaning;
Replenishment of engine coolant;
Replenishment of water;
Sanitize potable water;
Adjustment of tyre pressures;
Replenishment of de-icing fluid;
Periodic lubrication of components, other than lubrication that is required for the accomplishment of scheduled maintenance, which does not require disassembly of the component, other than removal of non-structural items such as cover plates, cowlings and fairings eg: lubrication of door hinges;
Aircraft internal and external cleaning, including windscreen cleaning;
Disinfecting of the aircraft;
Removal of ice and snow;
Application of preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good maintenance practices;
Checking aircraft battery electrolyte levels and topping up with distilled water but excluding wet cell nickel-cadmium batteries;
Servicing tasks required by the aircraft flight manual or maintenance manual;
Towing, parking and mooring including tasks to facilitate these functions eg: quick disconnect and re-connection of torque links; and
Replacement or repair of signs and markings.
Note: The servicing of liquid and gaseous oxygen systems is to be carried out only by an appropriately rated LAME.
As mentioned earlier, if any of these are written into the aircraft Approved Maintenance Program (not a policy or procedure manual) then they are maintenance tasks.
Further factual reading here:
Civil Aviation Safety Authority - AWB 12-1 Issue 2 - Aircraft servicing and ground handling tasks
Again, that's not to say that any of this is appropriate for any particular operator. But these are the actual regulator guidelines.
MP.
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Just to remind everybody, Fedsec started this thread in order to get some feedback with respect to Qantas's maintenance system and 48 hour checks on THEIR aircraft.
Some fair and reasonable posts have been made about what constitutes a breach of the current regulations and what does not.
The feedback requested was not about any other owners aircraft, but discussion raised some salient points about pilots duties and privileges in a much broader sense.
Having said that, I think t's better to keep the focus on the thrust of Fedsec's letters to CASA and what help he is hoping to get from this thread.
The point about what constitutes a cancellation of the CRS is very interesting and how Qantas's Maintenance Progam fits with the current regulations so there might be something there to mull on.
In the light of keeping SAFETY for all at the top of the list in running an airline, costs reduction by Qantas (and others) has meant testing the boundaries of the regulations. In my view, I have to say that this is being done with the complicity of the regulator. Others might not agree with that.
So it might be more helpful to provide something that shows the issues that are conflicting the maintenance program with the regulations on these aircraft.
Some fair and reasonable posts have been made about what constitutes a breach of the current regulations and what does not.
The feedback requested was not about any other owners aircraft, but discussion raised some salient points about pilots duties and privileges in a much broader sense.
Having said that, I think t's better to keep the focus on the thrust of Fedsec's letters to CASA and what help he is hoping to get from this thread.
The point about what constitutes a cancellation of the CRS is very interesting and how Qantas's Maintenance Progam fits with the current regulations so there might be something there to mull on.
In the light of keeping SAFETY for all at the top of the list in running an airline, costs reduction by Qantas (and others) has meant testing the boundaries of the regulations. In my view, I have to say that this is being done with the complicity of the regulator. Others might not agree with that.
So it might be more helpful to provide something that shows the issues that are conflicting the maintenance program with the regulations on these aircraft.
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As mentioned earlier, if any of these are written into the aircraft Approved Maintenance Program (not a policy or procedure manual) then they are maintenance tasks.
Sanitize potable water
Yes there has been good discussion about the implications of accountants running there eyes over maintenance and engineering functions.
However, since fed sec raised the issue what's happened?
Traditionally you got to the aircraft, as a pilot, had a glance at the oils, and 99.9% of the time they'd be at or above 18qts. This no longer occurs. You can find any values from 11-18 qts.
The crux of the problem for the pilot in this brave new world, is wtf is the manufacturers recommended minimum? And lets move up from there.
A memo has been published with numbers, but is this an official document in CASa's eyes, or even a Qantas operational perspective?
I think not. People can bang on here about what pilots and engineers should cop but the fact is,from a legal stand point, you've got the right and need to ask is it acceptable? Clearly not.
So now you have a ridiculous scenario where engineers are saying under the new 48 hour requirements they simply cannot inspect the oil levels on a quick turnaround because they fear it will be read as some form of industrial action by Qantas, pilots and engineers saying the place has gone completely bonkers, pilots then placing tech log entries about oil levels for fear that 8 hours flying to non maintenance ports could run the oil levels below minimums, what ever that number is.
And where is compliance in all of this?
However, since fed sec raised the issue what's happened?
Traditionally you got to the aircraft, as a pilot, had a glance at the oils, and 99.9% of the time they'd be at or above 18qts. This no longer occurs. You can find any values from 11-18 qts.
The crux of the problem for the pilot in this brave new world, is wtf is the manufacturers recommended minimum? And lets move up from there.
A memo has been published with numbers, but is this an official document in CASa's eyes, or even a Qantas operational perspective?
I think not. People can bang on here about what pilots and engineers should cop but the fact is,from a legal stand point, you've got the right and need to ask is it acceptable? Clearly not.
So now you have a ridiculous scenario where engineers are saying under the new 48 hour requirements they simply cannot inspect the oil levels on a quick turnaround because they fear it will be read as some form of industrial action by Qantas, pilots and engineers saying the place has gone completely bonkers, pilots then placing tech log entries about oil levels for fear that 8 hours flying to non maintenance ports could run the oil levels below minimums, what ever that number is.
And where is compliance in all of this?
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PM, Would you like to read the background to your post and does it apply today?
'Maintenance means…the doing of any work (including a modification or repair) on the aircraft that may affect the safety of the aircraft or cause the aircraft to become a danger to person or property…'
'Servicing…means preparing the aircraft for flight, and includes providing the aircraft with fuel and other fluids…but does not include any work that is maintenance.'
Certification for the completion of servicing tasks is not required when preparing the aircraft for flight, unless specifically required as part of an approved system of maintenance.
Certification is required when performing servicing tasks in conjunction with a maintenance activity.
I guess checking engine oil levels is maintenance task then.
SRM
'Maintenance means…the doing of any work (including a modification or repair) on the aircraft that may affect the safety of the aircraft or cause the aircraft to become a danger to person or property…'
'Servicing…means preparing the aircraft for flight, and includes providing the aircraft with fuel and other fluids…but does not include any work that is maintenance.'
Certification for the completion of servicing tasks is not required when preparing the aircraft for flight, unless specifically required as part of an approved system of maintenance.
Certification is required when performing servicing tasks in conjunction with a maintenance activity.
I guess checking engine oil levels is maintenance task then.
SRM
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Most jets sitting around overnight gulp oil.if the crew get on and it's below minimums two choices,call an appropriate lame and enter in tech log start engines and idle for five minutes like the meerkat says simplez
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Regardless of whether a job is considered a servicing task or a maintenance task, it must be done IAW the relevant AMM which covers any warnings or cautions applicable to the task. Some of the most basic tasks have the requirement to safety or lock out a system.
If you are legal to do something , by all means do it if u must. But do it properly.
These rules are a dogs breakfast at the best of times .
If qantas want to adopt industry standards ... Let the pilots do the oils and servicing and give engineers aircraft taxi authority !
It's in the AMM! :-)
If you are legal to do something , by all means do it if u must. But do it properly.
These rules are a dogs breakfast at the best of times .
If qantas want to adopt industry standards ... Let the pilots do the oils and servicing and give engineers aircraft taxi authority !
It's in the AMM! :-)
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SRM,
"Certification for the completion of servicing tasks is not required when preparing the aircraft for flight, unless specifically required as part of an approved system of maintenance.
Certification is required when performing servicing tasks in conjunction with a maintenance activity."
Correct, good to see you've done some homework.......though you missed my initial point entirely; the opening of a quick release panel does not invalidate the CRS. The carrying out of a maintenance activity invalidates the CRS. A check 1 or 2 requires you to check the oils amongst other things; the check or a defect entry is what kills the CRS.
Some operators require oil servicing at certain locations but not as part of their SOM but rather a convenience; usually prior to a sequence of unmanned legs. Also some MROs will check your oils on every turn (Good for the bottom line). Assuming all is within consumption rates this does not invalidate the CRS.
As an aside; this has created some healthy discussion which highlights how poor our new regulations are..........you had to go to the ACT to get to the meaning of "maintenance".......... and where did you go for "servicing"???
"Certification for the completion of servicing tasks is not required when preparing the aircraft for flight, unless specifically required as part of an approved system of maintenance.
Certification is required when performing servicing tasks in conjunction with a maintenance activity."
Correct, good to see you've done some homework.......though you missed my initial point entirely; the opening of a quick release panel does not invalidate the CRS. The carrying out of a maintenance activity invalidates the CRS. A check 1 or 2 requires you to check the oils amongst other things; the check or a defect entry is what kills the CRS.
Some operators require oil servicing at certain locations but not as part of their SOM but rather a convenience; usually prior to a sequence of unmanned legs. Also some MROs will check your oils on every turn (Good for the bottom line). Assuming all is within consumption rates this does not invalidate the CRS.
As an aside; this has created some healthy discussion which highlights how poor our new regulations are..........you had to go to the ACT to get to the meaning of "maintenance".......... and where did you go for "servicing"???
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Mr PB,
Most of the operators in the Region require a certification for engine oils whether uplift is required or not, some even require a duplicate inspection if the oil cap is lifted.
I cannot recall any Large aircraft, say in last 50 years that required a flight crew member as part of their duties and included in the Aircraft Operating Manual to open a panel and do a physical check of the engine oil quantity.
I my previous life I never had any requirement to do so.
If opening a panel to carry out a physical check of the engine oil quantity is included as part of the aircrafts operating procedures then this of course this should be carried out. However, if a pilot opens a panel after I have released the aircraft to service, I have a problem.
REASON: If the panel is left open and I was the last person to certify it was closed, I will get in the SH!T.
Get my point.
Most of the operators in the Region require a certification for engine oils whether uplift is required or not, some even require a duplicate inspection if the oil cap is lifted.
I cannot recall any Large aircraft, say in last 50 years that required a flight crew member as part of their duties and included in the Aircraft Operating Manual to open a panel and do a physical check of the engine oil quantity.
I my previous life I never had any requirement to do so.
If opening a panel to carry out a physical check of the engine oil quantity is included as part of the aircrafts operating procedures then this of course this should be carried out. However, if a pilot opens a panel after I have released the aircraft to service, I have a problem.
REASON: If the panel is left open and I was the last person to certify it was closed, I will get in the SH!T.
Get my point.
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I can assure you that it is not within QF policy/procedures for a pilot to open an engine panel and carry out a physical oil quantity inspection. If you need me to quote documentation to prove it, you obviously have no place flying or maintaining a QF aircraft. If you can't find a QF procedure that tells you to do it, but you still think it's a good idea to give it a go because you read some obscure CASA reg that you think covers it, please give me some of whatever it is you are smoking!
Last edited by CoolB1Banana; 28th Apr 2014 at 10:35. Reason: Typo
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SRM/Coolb1banana,
The pair of you have not got the point at all!! Have I said anything about engine oil inspection or checking...........NO!! SRM you seem obsessed with checking and leaving oil service panels open. Have you left them open before?? Was it the pilots fault??
Leaving open a refuel panel may be a lot worse but you have no consideration of this.
You have shoved it up a post that QF do not operate light twins............in the old days these were called F27s (Blue team I'm sorry).
The pilots had to some times check engine oils; even the gearboxes!!!
You have assumed I am a pilot.........WRONG!!! I wish I were!!
You quote your QEPM as the gospel (as you must)..........but it is the biggest piece of ****e in the industry!!
One day the pair of you will grow up to understand the system around you!!
Regards
PB
The pair of you have not got the point at all!! Have I said anything about engine oil inspection or checking...........NO!! SRM you seem obsessed with checking and leaving oil service panels open. Have you left them open before?? Was it the pilots fault??
Leaving open a refuel panel may be a lot worse but you have no consideration of this.
You have shoved it up a post that QF do not operate light twins............in the old days these were called F27s (Blue team I'm sorry).
The pilots had to some times check engine oils; even the gearboxes!!!
You have assumed I am a pilot.........WRONG!!! I wish I were!!
You quote your QEPM as the gospel (as you must)..........but it is the biggest piece of ****e in the industry!!
One day the pair of you will grow up to understand the system around you!!
Regards
PB
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Mr PB grow up mate!
As a B1 LAME I am not talking about GA, I am talking about Large aircraft that are covered by a System of Maintenance.
Every time a Lame signs for an item he has to do so IAW approved data.
If a pilot opens a panel that is not included on his pre-flight check OR has not been trained and approved by a Part 145 or an approved training organisation to do so, he will cancel the CRS this is a FACT!
This is called undocumented maintenance.
Read the Regulations or if you like check with CASA.
As a B1 LAME I am not talking about GA, I am talking about Large aircraft that are covered by a System of Maintenance.
Every time a Lame signs for an item he has to do so IAW approved data.
If a pilot opens a panel that is not included on his pre-flight check OR has not been trained and approved by a Part 145 or an approved training organisation to do so, he will cancel the CRS this is a FACT!
This is called undocumented maintenance.
Read the Regulations or if you like check with CASA.
Hmmm, a notice has now been issued stating min oil for start is 12 litres. And that's all you need to worry about. Shame the number in the fleet blog is different!!!!
So the world is a happy place. Off you go boys and girls.
But hang on, lets say I'm going Sydney Karratha Perth for the day?
I take it starting in Sydney with 12 litres, everything is Kosher?
So the world is a happy place. Off you go boys and girls.
But hang on, lets say I'm going Sydney Karratha Perth for the day?
I take it starting in Sydney with 12 litres, everything is Kosher?