No RPT LAME requirement
I agree: LAME's prefilght inspection / intransit checks / signatures have never been required in Australia!
How do you think RPT services operate through Kalgoorlie, Kununurra, Karratha, Ayes Rock etc. etc. Walkarounds and refuelling were completed by the flight crew, without certifying anything. On the Argyll overnight, the aircraft was shutdown, covers placed, left overnight, refuelled, covers removed, started up and flown all without any paperwork - nor was any required.
In all of the regs posted here, I see no requirement for a pre-flight certification, only that a signed MR be present. Signed four days ago, or whatever meets the requirements.
Even in Ansett operations, I would have been happy with the ground staff (i.e. loaders) pushing back the aircraft, disconnecting the tow bar, and replacing the steering pin without LAME's. Should have operated that way years ago and saved a few more dollars!
How do you think RPT services operate through Kalgoorlie, Kununurra, Karratha, Ayes Rock etc. etc. Walkarounds and refuelling were completed by the flight crew, without certifying anything. On the Argyll overnight, the aircraft was shutdown, covers placed, left overnight, refuelled, covers removed, started up and flown all without any paperwork - nor was any required.
In all of the regs posted here, I see no requirement for a pre-flight certification, only that a signed MR be present. Signed four days ago, or whatever meets the requirements.
Even in Ansett operations, I would have been happy with the ground staff (i.e. loaders) pushing back the aircraft, disconnecting the tow bar, and replacing the steering pin without LAME's. Should have operated that way years ago and saved a few more dollars!
Last edited by Checkboard; 17th May 2002 at 04:23.
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Yes, and you know how to tell these operators from the others?
The Aircraft will magically fly around for several days without any problems at all, because the Pilots quite unethically do not write any defects in, then finally the Aircraft arrives at a maintenance base overnight, and suddenly it has pages of defects written up needing attention.
God help us if this becomes common in Australia.
The Aircraft will magically fly around for several days without any problems at all, because the Pilots quite unethically do not write any defects in, then finally the Aircraft arrives at a maintenance base overnight, and suddenly it has pages of defects written up needing attention.
God help us if this becomes common in Australia.
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ANLAME, in your second sentence above, you left out the qualifier "unless we notify a difference."
That is not to say that I disagree with the general thrust of your gripe.
Gru
That is not to say that I disagree with the general thrust of your gripe.
Gru
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gtg
I'll take another tack. Who determines the airworthiness of the aircraft as per the ICAO reference? More importantly, ho has the qualifications to make the determination. This is what I'm getting at. We've got off track with the MR. You are correct about QF and the -800s. They are trying to tread quitely and the ALAEA is currently pursuing the matter with a branch of CASA that doesn't jump like a red rat.
airsupport raises a good point. Did the Kendell CRJ pilots realise that when they were pushed back at MEL, the NLG TORQUE LINK was reconnected by Burger Flippers. And as far as overnight defects are concerned that has been happening for couple of years, particularly when one crew has the aircraft for a number of legs and are then signing off. And make no mistake, the pressure to not enter defects in the log will multiply. Look at DJ in MEL. Most days they have no avionic coverage because they're a tightarse chicken sh!t outift, so miraculously there are no avionic snags transitting MEL.
But thats OK for wizkid beancounter types like checkboard who must surely be a management pilot. I hope that's the pilots perspective Tech Log you moderate. It's that type of attitude that gives you blokes a bad name.
I'll take another tack. Who determines the airworthiness of the aircraft as per the ICAO reference? More importantly, ho has the qualifications to make the determination. This is what I'm getting at. We've got off track with the MR. You are correct about QF and the -800s. They are trying to tread quitely and the ALAEA is currently pursuing the matter with a branch of CASA that doesn't jump like a red rat.
airsupport raises a good point. Did the Kendell CRJ pilots realise that when they were pushed back at MEL, the NLG TORQUE LINK was reconnected by Burger Flippers. And as far as overnight defects are concerned that has been happening for couple of years, particularly when one crew has the aircraft for a number of legs and are then signing off. And make no mistake, the pressure to not enter defects in the log will multiply. Look at DJ in MEL. Most days they have no avionic coverage because they're a tightarse chicken sh!t outift, so miraculously there are no avionic snags transitting MEL.
But thats OK for wizkid beancounter types like checkboard who must surely be a management pilot. I hope that's the pilots perspective Tech Log you moderate. It's that type of attitude that gives you blokes a bad name.
AN LAME
When you quoted subregulation 42ZC(2), you omitted to list the persons who are permitted by regulation 42ZC to do the maintenance. Most of the persons on the list are not, or are not required under the regulations to be, LAMEs.
For instance, a person is permitted to conduct maintenance on Class A aircraft if:
CASA can (note I did not say "should"), or a person authorised under subregulation 42ZC(7) can (note again I did not say "should"), authorise anyone under subregulation 42ZC(6) to carry out any and all maintenance on Class A aircraft.
Another alternative is:
The aircraft’s approved system of maintenance can (note again I did not say "should") authorise the pilot of a Class A aircraft to carry out any and all maintenance.
Checkboard: I am intrigued by your statement that:
Wasn’t a daily inspection required? Daily inspections constitute maintenance, and require certification. What about a fuel inspection? You will also see from what has been quoted above, the pilot of a Class A aircraft is not permitted to conduct maintenance on the aircraft unless the aircraft’s system of maintenance authorises her to do that inspection (or the pilot is otherwise qualified under 42ZC(3) to perform the inspection). If the pilot is not so authorised, the CofR holder, operator and PIC commit a naughty: 42ZC(2).
When you quoted subregulation 42ZC(2), you omitted to list the persons who are permitted by regulation 42ZC to do the maintenance. Most of the persons on the list are not, or are not required under the regulations to be, LAMEs.
For instance, a person is permitted to conduct maintenance on Class A aircraft if:
(3)(d) the person is authorised by CASA under subregulation (6), or an authorised person under subregulation (7), to carry out the maintenance and the maintenance is carried out in accordance with any conditions subject to which the authorisation is given;
Another alternative is:
(3)(c) the person is a pilot of the aircraft and is authorised to carry out the maintenance by the aircraft's approved system of maintenance;
Checkboard: I am intrigued by your statement that:
… On the Argyll overnight, the aircraft was shutdown, covers placed, left overnight, refuelled, covers removed, started up and flown all without any paperwork - nor was any required.
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No, AN LAME, actually I think what you were getting at was that CASA are ridding the requirement of LAME's doing the pre-flight and re-fuelling checks and certifications. What I ask is where in the regulations does it state that LAME's have to do pre-flight inspections before every flight and certify such? I refer to my previous post....
I am yet to see any information rendering my impressions incorrect.
As for your comment:
Well if you refer to Annex 8 Part II Chapter 4 Para 4.1(a),
The continuing airworthiness of an aircraft shall be
determined by the State of Registry in relation to the
appropriate airworthiness requirements in force for that
aircraft.
So it seems that actually CASA determines airworthiness.
Yes, from what I understand, Ramp staff pushed back the Kendell jets and reconnected the torque-links. No LAME pre-flight inspections there.....
Airsupport, I would almost hazard a guess that it already is common place.
CreamPuff, I imagine it probably was a part of their MSM.
Cheers!
GTG!
. I still believe (well, my interpretation,) that in the current CAR's that there is no requirement for LAME's to carry out or indeed certify for a walk-around/pre-flight inspection.
As for your comment:
Who determines the airworthiness of the aircraft as per the ICAO reference?
The continuing airworthiness of an aircraft shall be
determined by the State of Registry in relation to the
appropriate airworthiness requirements in force for that
aircraft.
So it seems that actually CASA determines airworthiness.
Yes, from what I understand, Ramp staff pushed back the Kendell jets and reconnected the torque-links. No LAME pre-flight inspections there.....
Airsupport, I would almost hazard a guess that it already is common place.
CreamPuff, I imagine it probably was a part of their MSM.
Cheers!
GTG!
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Would it be fair to say that Australia has an impeccable air safety record over a long period by finding all these loopholes,and reducing costs.Not.
I believe Mr Smith wanted to bring our standards down until the shaker went off and then creep it up a bit.How was that received by flight crew.I think AN LAME is trying to say avoid this.In reality it does costs lives.
A lose rivet letting go in an intake can and has cost millions of $$,would a non trained person pick these minute defects up on walkaround.Thats just one example for the beancounters of today.Wages Vs Repairs.Ask Air Japan about a row of rivets in a 747.Maybe a full night in the hangar might change their minds.
Why not go without hull insurance while were at it.Whats the return on it over the last 75 years.
There has to be a happy medium there somewhere.
I believe Mr Smith wanted to bring our standards down until the shaker went off and then creep it up a bit.How was that received by flight crew.I think AN LAME is trying to say avoid this.In reality it does costs lives.
A lose rivet letting go in an intake can and has cost millions of $$,would a non trained person pick these minute defects up on walkaround.Thats just one example for the beancounters of today.Wages Vs Repairs.Ask Air Japan about a row of rivets in a 747.Maybe a full night in the hangar might change their minds.
Why not go without hull insurance while were at it.Whats the return on it over the last 75 years.
There has to be a happy medium there somewhere.
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CAR 42 ZC(7) is the most abused piece of regulation when it comes to approving unqualified people to carry out maintenance. AND it is in direct conflict with ICAO Annex 1:
· Annex 1 Chapter 4.2.2.1: Subject to compliance with the requirements specified in 4.2.2.2 and 4.2.2.3, the privileges of the holder of an aircraft maintenance licence shall be to certify the aircraft or parts of the aircraft as airworthy after an authorized repair, modification or installation of a powerplant, accessory, instrument, and/or item of equipment, and to sign a maintenance release following inspection, maintenance operations and/or routine servicing.
· Annex 1 Chapter 4.2.2.1: Subject to compliance with the requirements specified in 4.2.2.2 and 4.2.2.3, the privileges of the holder of an aircraft maintenance licence shall be to certify the aircraft or parts of the aircraft as airworthy after an authorized repair, modification or installation of a powerplant, accessory, instrument, and/or item of equipment, and to sign a mainten-ance release following inspection, maintenance operations and/or routine servicing.
Therefore, if CASA are to comply with ICAO SARPs, no maintenance may be carried out by piulots on Transport category aircraft. I do comcede that this certainly is not the reality.
mainwheel is correct in his observation of the oncosts; hull & liability insurance;scheduling delays; missed connections; leasing companies inflating lease rates due to minimal maintenance(HYX/HYY could only carry something in the order of 3 MELs and half a dozen odd open defects or the leas rate soared); tech crews expected to make determinations for which they are not trained resulting in missed defects and ensuing inflated repair costs or worse - false economy at its best. And you know who will be held liable when it hits the fan? The crew - hopefully not RIP.
What industry should be doing - and I mean those of us at the pointy end - tech crew and maintenance engineers- is to band together and say enough is enough. We will not accept further deterioration in safety standards.
CASA must discharge the level of independent oversight the public of Australia deserves and ensure that commercial and contractual relationships cannot fragment safety management and control systems.( I'll just hop down off my soapbox now!)
CAR 42 ZC(7) is the most abused piece of regulation when it comes to approving unqualified people to carry out maintenance. AND it is in direct conflict with ICAO Annex 1:
· Annex 1 Chapter 4.2.2.1: Subject to compliance with the requirements specified in 4.2.2.2 and 4.2.2.3, the privileges of the holder of an aircraft maintenance licence shall be to certify the aircraft or parts of the aircraft as airworthy after an authorized repair, modification or installation of a powerplant, accessory, instrument, and/or item of equipment, and to sign a maintenance release following inspection, maintenance operations and/or routine servicing.
· Annex 1 Chapter 4.2.2.1: Subject to compliance with the requirements specified in 4.2.2.2 and 4.2.2.3, the privileges of the holder of an aircraft maintenance licence shall be to certify the aircraft or parts of the aircraft as airworthy after an authorized repair, modification or installation of a powerplant, accessory, instrument, and/or item of equipment, and to sign a mainten-ance release following inspection, maintenance operations and/or routine servicing.
Therefore, if CASA are to comply with ICAO SARPs, no maintenance may be carried out by piulots on Transport category aircraft. I do comcede that this certainly is not the reality.
mainwheel is correct in his observation of the oncosts; hull & liability insurance;scheduling delays; missed connections; leasing companies inflating lease rates due to minimal maintenance(HYX/HYY could only carry something in the order of 3 MELs and half a dozen odd open defects or the leas rate soared); tech crews expected to make determinations for which they are not trained resulting in missed defects and ensuing inflated repair costs or worse - false economy at its best. And you know who will be held liable when it hits the fan? The crew - hopefully not RIP.
What industry should be doing - and I mean those of us at the pointy end - tech crew and maintenance engineers- is to band together and say enough is enough. We will not accept further deterioration in safety standards.
CASA must discharge the level of independent oversight the public of Australia deserves and ensure that commercial and contractual relationships cannot fragment safety management and control systems.( I'll just hop down off my soapbox now!)
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AN LAME,
With regard to your last paragraph, YES that is what everyone should be doing.
However, VERY SADLY, that is never going to happen. Just read previous comments here on this thread, not only will some Pilots gladly go along with it, they say it should have been done years ago.
Can you even begin to imagine what Pilots would say if the Airlines came up with this great idea to save money, have some of their flights crewed by Engineers and Flight Attendants instead of Pilots. You think they would object?
They sure would, and rightly so to, how then do they possibly justify Pilots with little or no training, taking over the work of LAMEs, who have probably spent in most cases a Lifetime in Aircraft Engineering?
Any Pilots care to "please explain"?
Best regards,
airsupport.
With regard to your last paragraph, YES that is what everyone should be doing.
However, VERY SADLY, that is never going to happen. Just read previous comments here on this thread, not only will some Pilots gladly go along with it, they say it should have been done years ago.
Can you even begin to imagine what Pilots would say if the Airlines came up with this great idea to save money, have some of their flights crewed by Engineers and Flight Attendants instead of Pilots. You think they would object?
They sure would, and rightly so to, how then do they possibly justify Pilots with little or no training, taking over the work of LAMEs, who have probably spent in most cases a Lifetime in Aircraft Engineering?
Any Pilots care to "please explain"?
Best regards,
airsupport.
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Yep. You're absolutely correct. But I still had to ask. Most of the ignorant comments in the thread simply indicate a lack of professional courtesy and an' I'm Lord of all I see' mentality. However, I firmly believe that there are a large number of pilots who do respect the work of engineers but when it comes to standing up to their employers, the spectre of 1989 looms too large - unless it threatens their positions as you suggested. Looks like the ALAEA and their members are on their lonesome again.Sad isn't it!
Yep. You're absolutely correct. But I still had to ask. Most of the ignorant comments in the thread simply indicate a lack of professional courtesy and an' I'm Lord of all I see' mentality. However, I firmly believe that there are a large number of pilots who do respect the work of engineers but when it comes to standing up to their employers, the spectre of 1989 looms too large - unless it threatens their positions as you suggested. Looks like the ALAEA and their members are on their lonesome again.Sad isn't it!
AN LAME
We need to resolve two preliminary questions.
First: does the Chicago Convention require that a new maintenance release be issued prior to each and every flight?
Secondly: does the Chicago Convention require that maintenance on transport category aircraft be carried out and certified only by a licensed aircraft maintenance engineer?
I think the answer to both questions is “no”.
Assuming I’m wrong on these questions, your argument should run something like this:
1. Section 11 of the Civil Aviation Act 1988 provides that:
2. Breach of section 11 is a breach of the Civil Aviation Act 1988 and therefore unlawful. A person with sufficient interest is entitled to sue for a declaration that the CASA has acted in breach of the Act and, in an appropriate case, obtain an injunction restraining that body from taking any further action based on its unlawful action: Project Blue Sky v Australian Broadcasting Authority [1998] HCA 28 at 100.
3. CASA is therefore obliged when exercising its powers to approve systems of maintenance under subregulation 42M of the Civil Aviation Regulations 1988, to do so in a manner consistent with Australia’s obligations under at least the Chicago Convention.
4. Under the Chicago Convention, Australia is obliged to ensure that a new maintenance release is issued in respect of a transport category aircraft prior to each and every flight of the aircraft. [Good luck with that argument.]
5. Subregulation 47(5) Civil Aviation Regulations 1988 provides that:
6. Regulation 42L of the Civil Aviation Regulations 1988 provides that a system of maintenance for an aircraft must include, among other things:
7. Section 11 of the Civil Aviation Act 1988 therefore prohibits CASA from approving a system of maintenance when exercising its powers under subregulation 42M of the Civil Aviation Regulations 1988 in respect of a transport category aircraft, unless the system among other things requires a maintenance inspection before each flight, and nominates each of those inspections to be carried out for the purposes of determining whether a maintenance release should be issued for the aircraft.
8. CASA is therefore also obliged when exercising its powers under subregulation 42ZC(7) of the Civil Aviation Regulations 1988, to do so in a manner consistent with Australia’s obligations under at least the Chicago Convention.
9. Under the Chicago Convention, Australia is required to ensure that maintenance on transport category aircraft is carried out only by, and certified only by, licensed aircraft maintenance engineers. [Good luck with that argument.]
10. Although regulation 42ZC in its terms contemplates maintenance being conducted by persons other than licensed aircraft maintenance engineers, section 11 of the Civil Aviation Act 1988 limits the extent to which CASA may exercise its powers to permit that to happen.
11. CASA is therefore obliged under section 11 of the Civil Aviation Act 1988:
(a) not to approve a system of maintenance under subregulation 42M of the Civil Aviation Regulations 1988 if the system authorises the pilot of the aircraft to conduct maintenance on the aircraft, unless the pilot is the holder of an aircraft maintenance engineer’s licence; and
(b) not to approve a person under subregulation 42ZC(6) of the Civil Aviation Regulations 1988, unless the person is the holder of an aircraft maintenance engineer’s licence; and
(c) not to permit a person authorised for the purposes of subregulation 42ZC(7) of the Civil Aviation Regulations 1988 to authorise a person under subregulation 42ZC(7), unless the latter person is the holder of an aircraft maintenance engineer’s licence.
Give it a go in the Federal Court.
We need to resolve two preliminary questions.
First: does the Chicago Convention require that a new maintenance release be issued prior to each and every flight?
Secondly: does the Chicago Convention require that maintenance on transport category aircraft be carried out and certified only by a licensed aircraft maintenance engineer?
I think the answer to both questions is “no”.
Assuming I’m wrong on these questions, your argument should run something like this:
1. Section 11 of the Civil Aviation Act 1988 provides that:
CASA shall perform its functions in a manner consistent with the obligations of Australia under the Chicago Convention and any other agreement between Australia and any other country or countries relating to the safety of air navigation.
3. CASA is therefore obliged when exercising its powers to approve systems of maintenance under subregulation 42M of the Civil Aviation Regulations 1988, to do so in a manner consistent with Australia’s obligations under at least the Chicago Convention.
4. Under the Chicago Convention, Australia is obliged to ensure that a new maintenance release is issued in respect of a transport category aircraft prior to each and every flight of the aircraft. [Good luck with that argument.]
5. Subregulation 47(5) Civil Aviation Regulations 1988 provides that:
A maintenance release for an aircraft stops being in force when a maintenance release inspection of the aircraft begins.
(a) a schedule that:
(i) sets out the regular maintenance inspections, tests and checks to be carried out on the aircraft; and
(ii) sets out when those maintenance inspections, tests and checks are to be carried out; and
(ii) nominates one of the maintenance inspections referred to in subparagraph (i) as the inspection to be carried out for the purposes of determining whether a maintenance release should be issued for the aircraft.
(i) sets out the regular maintenance inspections, tests and checks to be carried out on the aircraft; and
(ii) sets out when those maintenance inspections, tests and checks are to be carried out; and
(ii) nominates one of the maintenance inspections referred to in subparagraph (i) as the inspection to be carried out for the purposes of determining whether a maintenance release should be issued for the aircraft.
8. CASA is therefore also obliged when exercising its powers under subregulation 42ZC(7) of the Civil Aviation Regulations 1988, to do so in a manner consistent with Australia’s obligations under at least the Chicago Convention.
9. Under the Chicago Convention, Australia is required to ensure that maintenance on transport category aircraft is carried out only by, and certified only by, licensed aircraft maintenance engineers. [Good luck with that argument.]
10. Although regulation 42ZC in its terms contemplates maintenance being conducted by persons other than licensed aircraft maintenance engineers, section 11 of the Civil Aviation Act 1988 limits the extent to which CASA may exercise its powers to permit that to happen.
11. CASA is therefore obliged under section 11 of the Civil Aviation Act 1988:
(a) not to approve a system of maintenance under subregulation 42M of the Civil Aviation Regulations 1988 if the system authorises the pilot of the aircraft to conduct maintenance on the aircraft, unless the pilot is the holder of an aircraft maintenance engineer’s licence; and
(b) not to approve a person under subregulation 42ZC(6) of the Civil Aviation Regulations 1988, unless the person is the holder of an aircraft maintenance engineer’s licence; and
(c) not to permit a person authorised for the purposes of subregulation 42ZC(7) of the Civil Aviation Regulations 1988 to authorise a person under subregulation 42ZC(7), unless the latter person is the holder of an aircraft maintenance engineer’s licence.
Give it a go in the Federal Court.
Last edited by Creampuff; 18th May 2002 at 04:46.
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AN LAME,
You will notice, as will any Pilots reading this, that in my previous posting I said "some Pilots".
There are many Pilots that do appreciate LAMEs, hopefully the majority, but sadly there are some that don't.
I have personally seen some Captains actually support a decision by a LAME over a defect, against the wishes of the Company.
Also I have been involved in training some Pilots on refuelling and preflight checks to a standard to get an approval from CASA, to do that work at non Engineering Airports. In their defence, almost all of them have done it reluctantly, saying that it is not really their job, well that's what they told me anyway.
Sadly though there are some that will gladly do this rather than support LAMEs.
You will notice, as will any Pilots reading this, that in my previous posting I said "some Pilots".
There are many Pilots that do appreciate LAMEs, hopefully the majority, but sadly there are some that don't.
I have personally seen some Captains actually support a decision by a LAME over a defect, against the wishes of the Company.
Also I have been involved in training some Pilots on refuelling and preflight checks to a standard to get an approval from CASA, to do that work at non Engineering Airports. In their defence, almost all of them have done it reluctantly, saying that it is not really their job, well that's what they told me anyway.
Sadly though there are some that will gladly do this rather than support LAMEs.
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AN LAME, First of all, I am still awaiting a response to my questions. You seem to have avoided the subject.
Also, and I quote:
Instead of comparing CAR42ZC Maintenance on Australian aircraft in Australian Territory, to Annex 1 Personnel Licensing, (In other words, apples and oranges) why don't you actually compare it to something more relevant, like (say), Annex 6 Chapter 8, Para 8.7.5, Approved Maintenance Orgainsation - Personnel. In other words the people who actually carry out the maintenance. It sure as hell doesn't say that everyone who works on aircraft has to be Approved as per Annex 1!
Here it is for your benefit.
Again, I await your response, and Oh, You have plenty of information/ammunition now, so I hope you do carry out your threat to '...throw it at CASA...', But I suspect you won't.
Mainwheel, I think you'll be hard pressed to find ANY LAME who inspects all the rivets on an aircraft let alone crawl into the stab-bay to inspect the read-pressure bulkhead on a turn-around...
Regards,
GTG!
Also, and I quote:
CAR 42 ZC(7) is the most abused piece of regulation when it comes to approving unqualified people to carry out maintenance. AND it is in direct conflict with ICAO Annex 1:
· Annex 1 Chapter 4.2.2.1: Subject to compliance with the requirements specified in 4.2.2.2 and 4.2.2.3, the privileges of the holder of an aircraft maintenance licence shall be to certify the aircraft or parts of the aircraft as airworthy after an authorized repair, modification or installation of a powerplant, accessory, instrument, and/or item of equipment, and to sign a maintenance release following inspection, maintenance operations and/or routine servicing.
· Annex 1 Chapter 4.2.2.1: Subject to compliance with the requirements specified in 4.2.2.2 and 4.2.2.3, the privileges of the holder of an aircraft maintenance licence shall be to certify the aircraft or parts of the aircraft as airworthy after an authorized repair, modification or installation of a powerplant, accessory, instrument, and/or item of equipment, and to sign a mainten-ance release following inspection, maintenance operations and/or routine servicing.
Therefore, if CASA are to comply with ICAO SARPs, no maintenance may be carried out by piulots on Transport category aircraft. I do comcede that this certainly is not the reality.
· Annex 1 Chapter 4.2.2.1: Subject to compliance with the requirements specified in 4.2.2.2 and 4.2.2.3, the privileges of the holder of an aircraft maintenance licence shall be to certify the aircraft or parts of the aircraft as airworthy after an authorized repair, modification or installation of a powerplant, accessory, instrument, and/or item of equipment, and to sign a maintenance release following inspection, maintenance operations and/or routine servicing.
· Annex 1 Chapter 4.2.2.1: Subject to compliance with the requirements specified in 4.2.2.2 and 4.2.2.3, the privileges of the holder of an aircraft maintenance licence shall be to certify the aircraft or parts of the aircraft as airworthy after an authorized repair, modification or installation of a powerplant, accessory, instrument, and/or item of equipment, and to sign a mainten-ance release following inspection, maintenance operations and/or routine servicing.
Therefore, if CASA are to comply with ICAO SARPs, no maintenance may be carried out by piulots on Transport category aircraft. I do comcede that this certainly is not the reality.
Here it is for your benefit.
8.7.5 Personnel
8.7.5.1 The maintenance organization shall nominate a
person or group of persons whose responsibilities include
ensuring that the maintenance organization is in compliance
with 8.7 the requirements for an approved maintenance
organization.
8.7.5.2 The maintenance organization shall employ the
necessary personnel to plan, perform, supervise, inspect and
release the work to be performed.
8.7.5.3 The competence of maintenance personnel shall
be established in accordance with a procedure and to a level
acceptable to the State granting the approval. The person
signing a maintenance release shall be qualified in accordance
with Annex 1.
8.7.5.4 The maintenance organization shall ensure that all
maintenance personnel receive initial and continuation training
appropriate to their assigned tasks and responsibilities. The
training programme established by the maintenance organiz-ation
shall include training in knowledge and skills related to
human performance, including co-ordination with other main-tenance
personnel and flight crew.
8.7.5.1 The maintenance organization shall nominate a
person or group of persons whose responsibilities include
ensuring that the maintenance organization is in compliance
with 8.7 the requirements for an approved maintenance
organization.
8.7.5.2 The maintenance organization shall employ the
necessary personnel to plan, perform, supervise, inspect and
release the work to be performed.
8.7.5.3 The competence of maintenance personnel shall
be established in accordance with a procedure and to a level
acceptable to the State granting the approval. The person
signing a maintenance release shall be qualified in accordance
with Annex 1.
8.7.5.4 The maintenance organization shall ensure that all
maintenance personnel receive initial and continuation training
appropriate to their assigned tasks and responsibilities. The
training programme established by the maintenance organiz-ation
shall include training in knowledge and skills related to
human performance, including co-ordination with other main-tenance
personnel and flight crew.
Mainwheel, I think you'll be hard pressed to find ANY LAME who inspects all the rivets on an aircraft let alone crawl into the stab-bay to inspect the read-pressure bulkhead on a turn-around...
Regards,
GTG!
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I was trying to point out how such small mistakes can bring a 747 to it's knee's.LAME's are trained to look for the abnormal,even on turnarounds.
Should we start a thread by LAME's about the stupid questions asked by other ground crew over the years,the same one's now doing the turnaround.
Would the punters,who really pay the bills,be happy to know that Aus registered aircraft on domestic flights are having their maintenance standards going towards those of 3rd world countries,all to save a few $$$.Have they a right to be told.
The attitude of a COO of an international airline in a se/asian 3rd world country airline was to give the most senior f/o a set of 4bar slides to replace the Captian that just resigned.I was working for them at the time.It was only the interference of an aussie Captain just hours before the flight that put a stop to it.would have saved some $$$ though.
Same thinking?.
Should we start a thread by LAME's about the stupid questions asked by other ground crew over the years,the same one's now doing the turnaround.
Would the punters,who really pay the bills,be happy to know that Aus registered aircraft on domestic flights are having their maintenance standards going towards those of 3rd world countries,all to save a few $$$.Have they a right to be told.
The attitude of a COO of an international airline in a se/asian 3rd world country airline was to give the most senior f/o a set of 4bar slides to replace the Captian that just resigned.I was working for them at the time.It was only the interference of an aussie Captain just hours before the flight that put a stop to it.would have saved some $$$ though.
Same thinking?.
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Although this no longer directly affects me, I would like to see things remain as they have always been.
Having made that clear, Australia is one of very few Countries where LAMEs, or any Engineers, still actually do the pushbacks. In most Countries the pushbacks are done by what we here would call the porters (TWU whatever), HOWEVER there are in most places LAMEs on tarmac to supervise the actual turnrounds and in case of defects etc. Maybe the Companies could look at this to save money?
Of course the Companies are their own worst enemies sometimes. They are now looking to save money on these turnrounds, so let's do away with expensive LAMEs. These same Companies have very short memories though, back years ago when there was much more industrial action, and the pushbacks were introduced, LAMEs and other Engineers had always done ALL the towing and moving of Aircraft, nobody else ever, except taxiing of course.
The TWU then insisted their members do all these new pushbacks, and indeed ALL the towing. The Companies were happy to give them the pushbacks over the Engineers who wanted to do it, but even after actual industrial stoppages would NOT agree to them doing ALL of the towing, even though a lot of Engineers were saying let them have it, they can tow at 2AM in the morning from the hangar in pouring rain.....
Why did the Companies refuse to give in to the TWU on this point, obviously they trusted the Engineers more? Yeah right. It was because if there was any industrial action by the TWU, all the Aircraft would be stuck at the gates.
These Companies have now obviously chosen to forget, how many times LAMEs had to tow Aircraft off line for "maintenance" into the hangar, have a quick cup of tea, then tow the Aircraft back on to the line in a position it could taxi out from.
Actually that would be a good point to put to the Management of these Airlines, IF they no longer require Engineers on tarmac, to save money, how about the TWU also do all the towing? IF there is anyone in Management that were with the Airlines back then, they will rethink the proposal.......
Having made that clear, Australia is one of very few Countries where LAMEs, or any Engineers, still actually do the pushbacks. In most Countries the pushbacks are done by what we here would call the porters (TWU whatever), HOWEVER there are in most places LAMEs on tarmac to supervise the actual turnrounds and in case of defects etc. Maybe the Companies could look at this to save money?
Of course the Companies are their own worst enemies sometimes. They are now looking to save money on these turnrounds, so let's do away with expensive LAMEs. These same Companies have very short memories though, back years ago when there was much more industrial action, and the pushbacks were introduced, LAMEs and other Engineers had always done ALL the towing and moving of Aircraft, nobody else ever, except taxiing of course.
The TWU then insisted their members do all these new pushbacks, and indeed ALL the towing. The Companies were happy to give them the pushbacks over the Engineers who wanted to do it, but even after actual industrial stoppages would NOT agree to them doing ALL of the towing, even though a lot of Engineers were saying let them have it, they can tow at 2AM in the morning from the hangar in pouring rain.....
Why did the Companies refuse to give in to the TWU on this point, obviously they trusted the Engineers more? Yeah right. It was because if there was any industrial action by the TWU, all the Aircraft would be stuck at the gates.
These Companies have now obviously chosen to forget, how many times LAMEs had to tow Aircraft off line for "maintenance" into the hangar, have a quick cup of tea, then tow the Aircraft back on to the line in a position it could taxi out from.
Actually that would be a good point to put to the Management of these Airlines, IF they no longer require Engineers on tarmac, to save money, how about the TWU also do all the towing? IF there is anyone in Management that were with the Airlines back then, they will rethink the proposal.......
Last edited by airsupport; 19th May 2002 at 05:49.
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GTG
Just a quick interim response - I'm not avoiding n answer I just try to spend the weekend with my family.
CAR 42 ZC& IS abig problem and it has nothing to do with the issue of who carries out the maintenance - qualifications are a whole other ball game - rather who certifies it.
And as far as throwing it at CASA, none of us know who we're chatting to, do we?
Just a quick interim response - I'm not avoiding n answer I just try to spend the weekend with my family.
CAR 42 ZC& IS abig problem and it has nothing to do with the issue of who carries out the maintenance - qualifications are a whole other ball game - rather who certifies it.
And as far as throwing it at CASA, none of us know who we're chatting to, do we?
It seems that there are three arguments running here:
Creampuff, Yes, a daily inspections and fuel sample were required (and performed). As I said above, those procedures were included in the AOM. I know that a daily is maintenace and requires certification, I don't know how that operated legally, but Ansett's procedures were always a bit of a joke when it came to pilots writing on the "engineer's" bits of the MR.
- A legal argument: That a Class A aircraft requires certification by a LAME before each flight, and that while that may not be the case under CASA'a regs, it should be the case under the Chicago convention.
The convention does not require certification before each flight and the arguments above show that, while CAR(1988) REG 42ZC fairly clearly states that a pilot may perform pre-flight and daily inspections, or refuelling tests, if:
Now while I wasn't privy to the documents detailing the aircraft system of maintenance, I do know that both the daily inspection and the refuelling checks were in the Aircraft Operating Manuals used by Ansett, and can only assume that those checks must have been included in the aircraft's system of maintenance.the person is a pilot of the aircraft and is authorised to carry out the maintenance by the aircraft's approved system of maintenance
As I said above, this argument also convieniently ignores the fact that aircraft transistion through ports without engineering facilities (and have done since the dawn of aviation). No government would legally require engineering at every landing port in any country around the world. - A Safety argument: LAME's are trained extensively in maintenance, and a pre-flight inspection by a LAME is much safer than one done by a pilot, as a pilot wouldn't know a worn rivet or missing static wick if it bit them on the arse.
Now while pilots don't recieve specific maintenance training, they certainly do recieve training in the daily inspection for a type and it's requirements. Given the (usually) extensive experience on Class B aircraft operations, in which pilots are specifically aproved for daily inspections by the regs, pilots are used to this type of work, and are cognizant of the fact that their and their passenger's safety rely upon the thoroughness of that inspection. I really doubt that a LAME would do a better job - it's not about fixing a defect, it's just about noticing one.
To suggest that a pilot isn't capable of this simple inspection, or that ground staff aren't capable of resetting a torque link is both slighting and conceited. - An industrial argument: , as evidenced by airsupport's comments:
If your argument is to keep LAMEs on the tarmac for pre-flight checks purely to increase the number of LAME jobs in the market - go for it. (See - not only was I not a management pilot, I served on the APA)Can you even begin to imagine what Pilots would say if the Airlines came up with this great idea to save money, have some of their flights crewed by Engineers and Flight Attendants instead of Pilots. You think they would object?
They sure would, and rightly so to, how then do they possibly justify Pilots with little or no training, taking over the work of LAMEs, who have probably spent in most cases a Lifetime in Aircraft Engineering?
I personally believe it is a waste of resources to have a highly qualified engineer hanging around a ramp to perform tasks that are simple, and in the case of pre-flight inpections, performed by the flight crew in any case.
Creampuff, Yes, a daily inspections and fuel sample were required (and performed). As I said above, those procedures were included in the AOM. I know that a daily is maintenace and requires certification, I don't know how that operated legally, but Ansett's procedures were always a bit of a joke when it came to pilots writing on the "engineer's" bits of the MR.
Last edited by Checkboard; 19th May 2002 at 09:26.
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Just a quick interim response - I'm not avoiding n answer I just try to spend the weekend with my family.
CAR 42 ZC& IS abig problem and it has nothing to do with the issue of who carries out the maintenance - qualifications are a whole other ball game - rather who certifies it.
And as far as throwing it at CASA, none of us know who we're chatting to, do we?
Just a quick interim response - I'm not avoiding n answer I just try to spend the weekend with my family.
CAR 42 ZC& IS abig problem and it has nothing to do with the issue of who carries out the maintenance - qualifications are a whole other ball game - rather who certifies it.
And as far as throwing it at CASA, none of us know who we're chatting to, do we?
I don't think CAR42ZC covers certification requirements nor who can certify for maintenance. Try CAR42ZE.
And my friend, believe me, I know who you are.
Regards.
GTG!
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Checkboard,
I think you have misread what I meant?
I sincerely believe this to be a safety issue.
As well as that it will of course not help the terrible unemployment currently in the Industry.
I was purely suggesting that the LAMEs may have to resort to some sort of industrial action, in order to address their safety concerns.
Every Airline thinks that Engineers are a waste of money, right up until they have a broken Aircraft. Just like a lot of people think Pilots are very overpaid, right up until they are flying with them and there is an onboard emergency.
One concern I would have with the Pilots doing the work that has traditionally been the Lames work, is if you were doing a series of flights with the same Aircraft. You may know everything about your Aircraft, be the best Pilot in Australia and an Ace on Preflights, but as an example suppose you were doing MEL-SYD-BNE-TSV overnight (no daily required overnight), then TSV-BNE-SYD-MEL the next day. I would have grave concerns, especially if I was one of your passengers, that only you were checking the Aircraft for 2 days. At least under the current system, there would be much more chance of different LAMEs noticing a defect.
Cheers,
airsupport.
I think you have misread what I meant?
I sincerely believe this to be a safety issue.
As well as that it will of course not help the terrible unemployment currently in the Industry.
I was purely suggesting that the LAMEs may have to resort to some sort of industrial action, in order to address their safety concerns.
Every Airline thinks that Engineers are a waste of money, right up until they have a broken Aircraft. Just like a lot of people think Pilots are very overpaid, right up until they are flying with them and there is an onboard emergency.
One concern I would have with the Pilots doing the work that has traditionally been the Lames work, is if you were doing a series of flights with the same Aircraft. You may know everything about your Aircraft, be the best Pilot in Australia and an Ace on Preflights, but as an example suppose you were doing MEL-SYD-BNE-TSV overnight (no daily required overnight), then TSV-BNE-SYD-MEL the next day. I would have grave concerns, especially if I was one of your passengers, that only you were checking the Aircraft for 2 days. At least under the current system, there would be much more chance of different LAMEs noticing a defect.
Cheers,
airsupport.