Should we do what the AMP says?
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Should we do what the AMP says?
OK, ladies and gents - I'm playing devil's advocate here but humour me and answer the following question (no penalty marking):
You are repping a maintenance check or doing a records review for an ARC. You look through the NRCs and see an APU door actuator has been replaced during the check. You leaf through the Forms 1 or 8130-3s and see that that the item fitted is "Repaired" or "Inspected/Tested". The AMP says that, at that check, the actuator has to be "Overhauled" (the original item could not be turned around in time). What do you do?
a) Accept dictacts from above that it be removed because you have to have an overhauled item as per the AMP (or have a brand new one fitted)
b) Accept dictacts from above saying it doesn't matter if the replacement is repaired or inspected because it has, after all, been replaced (and if an ovehauled item failed on the line after the SMI had been signed, you could legitimately fit an item other than overhauled)
c) You wonder how you got into this job
You are repping a maintenance check or doing a records review for an ARC. You look through the NRCs and see an APU door actuator has been replaced during the check. You leaf through the Forms 1 or 8130-3s and see that that the item fitted is "Repaired" or "Inspected/Tested". The AMP says that, at that check, the actuator has to be "Overhauled" (the original item could not be turned around in time). What do you do?
a) Accept dictacts from above that it be removed because you have to have an overhauled item as per the AMP (or have a brand new one fitted)
b) Accept dictacts from above saying it doesn't matter if the replacement is repaired or inspected because it has, after all, been replaced (and if an ovehauled item failed on the line after the SMI had been signed, you could legitimately fit an item other than overhauled)
c) You wonder how you got into this job
Last edited by Bus429; 11th Dec 2009 at 14:00.
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I think you're looking too deep! Said actuator needs to be overhauled as the AMP states - it has been removed and sent away for overhaul. A servicable item has been fitted in its place - all requirements met.
Unless the AMP states you need to fit an actuator with a specific life remaining then everything is good.
Thats my take on it anyway
Unless the AMP states you need to fit an actuator with a specific life remaining then everything is good.
Thats my take on it anyway
if you go over to Airmech, then the answer will always be...
b, (Kylie)
b, (Kylie)
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Ask for the history of the component, find out when it was last "overhauled", inform Part M organisation to reset the life of this particular AMP item to reflect last known overhaul. Job done.
You're the customer, aren't you?
You're the customer, aren't you?
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What Fargoo said. The AMP is stating that the Actuator currently fitted requires overhauling. By removing it and sending it for overhaul the AMP has been complied with. So long as the Actuator being fitted carries an 8130 or Form 1, everything is as it should be.
Answer b)
What would you do if the Actuator was "New" and not "overhauled"?
The AMP assumes that you are going to refit the same Item that has reached its overhaul Life. You have not done that. Instead, a substitute Item is installed with a suitable remaining life.
Job Done.
What would you do if the Actuator was "New" and not "overhauled"?
The AMP assumes that you are going to refit the same Item that has reached its overhaul Life. You have not done that. Instead, a substitute Item is installed with a suitable remaining life.
Job Done.
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Another couple of thoughts from the “repping” point of view as opposed to the purely “airworthiness”.
The organisation you are representing have contracted the maintenance organisation to replace the actuator with an “overhauled” item. You’ve got to assume that the intent is that they want a “newly overhauled” item fitted. For whatever reason the maintenance organisation (or your own organisation depending on how the contract is set up for supply of lifed components) cannot supply a newly overhauled component.
They have offered you a “repaired” component. How do you know that this repaired component has more life left on it to overhaul that the one that is already fitted to the aircraft? If it is your organisation supplying the component then fine, everybody knows about it and the aircraft is compliant.
If, however, it is the maintenance organisation offering you the “repaired” component then I would be thinking about pushing this one up the line to the planner in your own organisation. Why?
The organisation you are representing have contracted the maintenance organisation to replace the actuator with an “overhauled” item. You’ve got to assume that the intent is that they want a “newly overhauled” item fitted. For whatever reason the maintenance organisation (or your own organisation depending on how the contract is set up for supply of lifed components) cannot supply a newly overhauled component.
They have offered you a “repaired” component. How do you know that this repaired component has more life left on it to overhaul that the one that is already fitted to the aircraft? If it is your organisation supplying the component then fine, everybody knows about it and the aircraft is compliant.
If, however, it is the maintenance organisation offering you the “repaired” component then I would be thinking about pushing this one up the line to the planner in your own organisation. Why?
- There could be enough life left on the current actuator to allow it to remain fitted to the aircraft and another maintenance input planned for when a newly overhauled component is available. They could even apply a variation to the life rule to buy more time to get a suitable replacement. The task is removed from the list of work contracted for with the maintenance organisation and money is saved in that they do not pay the maintenance organisation for the manhours to replace the component and do not pay the component supplier for an actuator that has to be subsequently replaced anyway.
- If there is no life left on the installed actuator and the “repaired” component is accepted then the AMP life rule will have to be reset to the TSO of the replacement “repaired” component.
- A bit more controversial, the CRS statement says if I remember correctly “All work specified unless otherwise specified has been carried out …..”. It could be argued that all work specified has not been carried out. By informing your organisation to do 2. above you are doing enough to cover the “unless otherwise specified” bit.
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Sonic Bam, this is basically my take on it.
If the AMP states that the part is to be removed for overhaul, then you fit an overhauled part. You can always check with the company that supplied the part to confirm what was done to the part, would not be the first time the form 1 was incorrect.
If you do not fit an overhauled part, or do the checks as Sonic Bam has suggested, then the person signing the CRS has just invalidated the C of A of the a/c.
This is because you are no longer in compliance with the AMP or AMS.
That is how l view it.
If the AMP states that the part is to be removed for overhaul, then you fit an overhauled part. You can always check with the company that supplied the part to confirm what was done to the part, would not be the first time the form 1 was incorrect.
If you do not fit an overhauled part, or do the checks as Sonic Bam has suggested, then the person signing the CRS has just invalidated the C of A of the a/c.
This is because you are no longer in compliance with the AMP or AMS.
That is how l view it.
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how do you think life components should be or are controlled?
I also know that there may be for example an SRT for a lifed component to be removed at the appropriate time. But that doesn't constitute component life control, it is the means by which that task is called out at the proper time that constitutes life control and there are various methods available to achieve this. One airline may use AMOS, (with which Spotty M will be familiar), another may use a specialised component record module in a different MRO IT system, yet another may use direct manual control through component control cards in a "Kardex" system with weekly checks to monitor the forecast and issue the removal card at the proper time. I've worked with all of these methods and they all work (albeit with different problems.)
The part may move from one aircraft to another, it may, like a fire extinguisher squib, have an absolute life that is consumed even when the part is on a shelf in stores or it may, like a landing gear, have an undefined ultimate life that is only determined as a result of the initial tear-down inspection, and so on. Lifed part control is a complex business and is seldom the business of AMP routine tasks. Lifed components are controlled through individual hours/cycle monitoring, not through routine aircraft task cards as described in the original question.
Last edited by Blacksheep; 13th Dec 2009 at 09:48.
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Lifed part control is a complex business and is seldom the business of AMP routine tasks.
Otherwise it becomes an out-of-phase item, and the task might as well be removed from the AMP routine tasks and be controlled as a time-lifed item......as an engine would be.
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Next question. How would you know that a replacement APU Door Actuator (as in the example quoted) had been overhauled? Or to put it another way, what work would constitute overhaul of this component as opposed to repair? The CMM certainly provides no such definition, so the Form One / FAA 8130-3 wouldn't provide a clue.
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Yes l agree with you Blacksheep, and as you point out l know about AMOS, but it is the AMP which is the source document that drives you to replacing the part. It is up to each individual airline how this is achieved, by the use of AMOS, SRT's, work or record cards and so on.
As for the Form One, welcome to the problems that we face with these cert forms, l am told only a few statements can be used on a Form One.
One hopes that somewhere a CMM may be quoted, but this does not always happen.
The CMM should give the requirements of what is required for continued airworthiness and if not, then it can not be overhauled.
This is not always the case, try finding out what an U/C from an Airbus is overhauled in accordance with.
Also don't be 100% sure on an APU actuator being on condition, ETOPS requirements can come into play with old mod state actuators on some fleets.
So you can see nothing is ever just black and white, it is all about making our life difficult..
As for the Form One, welcome to the problems that we face with these cert forms, l am told only a few statements can be used on a Form One.
One hopes that somewhere a CMM may be quoted, but this does not always happen.
The CMM should give the requirements of what is required for continued airworthiness and if not, then it can not be overhauled.
This is not always the case, try finding out what an U/C from an Airbus is overhauled in accordance with.
Also don't be 100% sure on an APU actuator being on condition, ETOPS requirements can come into play with old mod state actuators on some fleets.
So you can see nothing is ever just black and white, it is all about making our life difficult.
.
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Landing gears are a particulat headache, with some component parts being lifed at the same life as the total gear, yet being without an individual serial number.
You mention ETOPS; the requirements specify a minimum modification status for aircraft parts and systems. These are controlled through configuration management. AMOS has a Configuration Management Module, other systems may not, relying only on FIN Codes to ensure that the configuration is complete. It is then up to the operator to manage what parts and modification status qualify for a FIN Code, thus permitting the system to accept their installation on the aircraft. It is a headache that I've had to address, both when managing Technical Services and as Head of IT.There is no standard method for controlling lifed items or ETOPS configurations.
And don't mention AD compliance...
You mention ETOPS; the requirements specify a minimum modification status for aircraft parts and systems. These are controlled through configuration management. AMOS has a Configuration Management Module, other systems may not, relying only on FIN Codes to ensure that the configuration is complete. It is then up to the operator to manage what parts and modification status qualify for a FIN Code, thus permitting the system to accept their installation on the aircraft. It is a headache that I've had to address, both when managing Technical Services and as Head of IT.There is no standard method for controlling lifed items or ETOPS configurations.
And don't mention AD compliance...
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Originally Posted by nodrama
Which is why if the AMP routine task says remove for overhaul, then it is o/hauled and refitted, or replaced with and o/hauled item to ensure it's life reaches the next AMP time interval.
Otherwise it becomes an out-of-phase item, and the task might as well be removed from the AMP routine tasks and be controlled as a time-lifed item......as an engine would be.
Otherwise it becomes an out-of-phase item, and the task might as well be removed from the AMP routine tasks and be controlled as a time-lifed item......as an engine would be.
Also as stated if you sign the aircraft off not in accordance with the AMP you may invalidate the C of A.