Part 145 defintion of complex tasks
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Part 145 definition of complex tasks
Ladies and gents,
Related a little to powerlimited's post elsewhere:
I'm not after the Part M Appendix VII definition of a complex task which largely relates to those tasks a Part 66 LAE cannot do unless operating under the auspices of a Part M Subpart F AMO.
I'd like a breakdown of the definition of complex in the context of Part 145.A.45 (Maintenance Data) (paraphrased): "...complex tasks shall be broken down etc... to allow task recording..."
Reason? We're trying with little success to get our certifying staff to do it and one - who rightly argues for the definition of a complex task - asked me to define it. He brought up the M Appendix VII definition above but I think this is literally out of context. I did argue for the application of a little common sense...
Related a little to powerlimited's post elsewhere:
I'm not after the Part M Appendix VII definition of a complex task which largely relates to those tasks a Part 66 LAE cannot do unless operating under the auspices of a Part M Subpart F AMO.
I'd like a breakdown of the definition of complex in the context of Part 145.A.45 (Maintenance Data) (paraphrased): "...complex tasks shall be broken down etc... to allow task recording..."
Reason? We're trying with little success to get our certifying staff to do it and one - who rightly argues for the definition of a complex task - asked me to define it. He brought up the M Appendix VII definition above but I think this is literally out of context. I did argue for the application of a little common sense...
Last edited by Bus429; 13th Nov 2011 at 16:04.
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Surely basic airmanship comes in to question? Are these guys licensed?
Paperwork even though we all hate it provides continuity in working practices and staged tasks.
An engine change cannot be 'replaced iaw xx-xx-xx/401 function satis' somewhere there must be staged breakdown of each task.
Paperwork even though we all hate it provides continuity in working practices and staged tasks.
An engine change cannot be 'replaced iaw xx-xx-xx/401 function satis' somewhere there must be staged breakdown of each task.
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Beeline,
I assure you that you are pushing at a wide-open door here; I've never been at a place where it has been so difficult to convince the AMO staff to do what the procedure says rather than what they want to do. We've brainstormed, discussed and agreed then many go ahead and disregard. We publish procedures, we have informal talks. We have a system where they can suggest changes, come up with better ideas.
Unfortunately, change of this type seems to affect what is fundamental to a commercial business: the bottom line, billable time etc.
I assure you that you are pushing at a wide-open door here; I've never been at a place where it has been so difficult to convince the AMO staff to do what the procedure says rather than what they want to do. We've brainstormed, discussed and agreed then many go ahead and disregard. We publish procedures, we have informal talks. We have a system where they can suggest changes, come up with better ideas.
Unfortunately, change of this type seems to affect what is fundamental to a commercial business: the bottom line, billable time etc.
Bus,
From the "indiscipline" you describe, you should make sure that all tasks are staged to wait for independant checks of the work before going on to other stages.
A sad indictment of the quality of your staff, I'm afraid.
Bee is quite right in stating what he has....but "complex" is whatever or whichever you (or your company) want to make it.
Complex depends on (naturally) the complexity of the work required, the quality of your staff, their qualifications, their competency and their capability.
If you feel 'they' need more stage checks and more supervision then it's your ball game - fill your boots and start the ball rolling.
hope this helps...
From the "indiscipline" you describe, you should make sure that all tasks are staged to wait for independant checks of the work before going on to other stages.
A sad indictment of the quality of your staff, I'm afraid.
Bee is quite right in stating what he has....but "complex" is whatever or whichever you (or your company) want to make it.
Complex depends on (naturally) the complexity of the work required, the quality of your staff, their qualifications, their competency and their capability.
If you feel 'they' need more stage checks and more supervision then it's your ball game - fill your boots and start the ball rolling.
hope this helps...
Rigga has provided some very sound advice.
I believe this requirement was introduced into 145.A.45 following the serious incident that occurred to an Excalibur A320 during in a line maintenance non scheduled flap change. The AAIB report published in 1994 is comprehensive and provides a great deal of background information that 145 AMOs could refer to when preparing their own procedures. It is well worth a read to be reminded of the traps and pitfalls that await the unwary or unprepared. http://www.aaib.gov.uk/cms_resources...5%20G-KMAM.pdf
Perhaps you could use this report for continuation training and if the AMO staff are not convinced and prepared to play ball in accordance with your procedures then perhaps they should be looking for a new job.
In addition the CAA published an Airworthiness Notice on the subject which is now included as appendix 5-2 in CAAIPs.
I believe this requirement was introduced into 145.A.45 following the serious incident that occurred to an Excalibur A320 during in a line maintenance non scheduled flap change. The AAIB report published in 1994 is comprehensive and provides a great deal of background information that 145 AMOs could refer to when preparing their own procedures. It is well worth a read to be reminded of the traps and pitfalls that await the unwary or unprepared. http://www.aaib.gov.uk/cms_resources...5%20G-KMAM.pdf
Perhaps you could use this report for continuation training and if the AMO staff are not convinced and prepared to play ball in accordance with your procedures then perhaps they should be looking for a new job.
In addition the CAA published an Airworthiness Notice on the subject which is now included as appendix 5-2 in CAAIPs.
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An engine change cannot be 'replaced iaw xx-xx-xx/401 function satis' somewhere there must be staged breakdown of each task.
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Thanks to all for the above.
Believe me, I've been in aviation since 77 and have acted as QA auditor, manager, Part M CAM, Subpart G QM, LAE, trainer - loads of stuff; I've run training in HF, Parts 145, M, FTS etc, etc. I've never experienced the reluctance I relate to you in the past.
What we were/are trying to achieve where I am now is no more onerous than I've seen elsewhere. Finally, I stood in front of a team of guys this morning and went through exactly what is required (after all that I'd described earlier) and I think we may have made some progress; audit will tell
Believe me, I've been in aviation since 77 and have acted as QA auditor, manager, Part M CAM, Subpart G QM, LAE, trainer - loads of stuff; I've run training in HF, Parts 145, M, FTS etc, etc. I've never experienced the reluctance I relate to you in the past.
What we were/are trying to achieve where I am now is no more onerous than I've seen elsewhere. Finally, I stood in front of a team of guys this morning and went through exactly what is required (after all that I'd described earlier) and I think we may have made some progress; audit will tell
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IMO, a normal entry in T/L would be " # 1 Engine changed IAW Worksheets or Task Card # xxxxx-xx where as those worksheets/task card ( duplicate insp.) must be signed by individual LAE"
Beeline is right to say that that big job like engine C/X cannot be c/o IAW AMM xx-xx-xx for reason of continuity and staged task.
Obviously, a wheel c/x can be simply c/o IAW AMM xx-xx-xx-xx (small AOC) or worksheets (shift change etc) or preferably with Task Cards (big organsations or hangar task).
Beeline is right to say that that big job like engine C/X cannot be c/o IAW AMM xx-xx-xx for reason of continuity and staged task.
Obviously, a wheel c/x can be simply c/o IAW AMM xx-xx-xx-xx (small AOC) or worksheets (shift change etc) or preferably with Task Cards (big organsations or hangar task).
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Do ignore Safety concerns. He is an ignorance office boy with no knowledge of Aircraft Engineering.
He is like Hitcher, the job worth guy in security posting sarcastic comments irritating all.
He is like Hitcher, the job worth guy in security posting sarcastic comments irritating all.
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I remember my CAA surveyor on his annual audit saying you now know you can rebuild wings etc under part M as he looks over and notices the barebones of a wing in the corner...
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Isn't there something coming out of EASA that requires the manufacturer to designate what are complex tasks?
Next time I lose the will to live I will go on to their website and see if I can find it.
Next time I lose the will to live I will go on to their website and see if I can find it.
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Let's face it the whole lot is daft.... I still think it is odd I can change an engine, refit a wing or complete tail assy and though there is dupes for any disturbed controls, there are none to check the wing or engine are correctly bolted on, I get someone to look over them for me as an extra check when they do the dupes, but there is no requirement for it.
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A LAE has the privilege of raising additional worksheet(s) to supplement task card which he deems inadequate. Any grey area can be brought up directly to QA/chief insp. etc to re-issue updated job task.
All AWS raised would be accounted for at the end of a check before final CRS.
What Bus's concern is the accountability of complex job done of UAE engineer (still under JAR system) who would just signed off (e.g. engine c/x) IAW AMM xx.xx.xx. END.
The engine is normally bolted on 2/3 attachment mounts and staged breakdown incl. dup.where required.
The Boeing wing is bolted by 2 bottle pins with bushes and staged breakdown incl. dup. where required.
Cessna???? I have forgotten!!
EASA requires detailed staged breakdown for individual accountability.
LAE is considered a professional engineer who is capable to signing off his own task without supervision and is under the jurisdiction of UK ANO (UK LAE) closely monitored by UK CAA.
Major task like wing removal requires flight test before issing C of A.
All AWS raised would be accounted for at the end of a check before final CRS.
What Bus's concern is the accountability of complex job done of UAE engineer (still under JAR system) who would just signed off (e.g. engine c/x) IAW AMM xx.xx.xx. END.
The engine is normally bolted on 2/3 attachment mounts and staged breakdown incl. dup.where required.
The Boeing wing is bolted by 2 bottle pins with bushes and staged breakdown incl. dup. where required.
Cessna???? I have forgotten!!
EASA requires detailed staged breakdown for individual accountability.
LAE is considered a professional engineer who is capable to signing off his own task without supervision and is under the jurisdiction of UK ANO (UK LAE) closely monitored by UK CAA.
Major task like wing removal requires flight test before issing C of A.
I'm sure my organisation isn't the only one that has many in-house engineering forms which are based on the AMM and detail all relavent steps to be taken with mech and LAE sign-off boxes for each task.
Examples include:
Engine change
APU change
FFG/MEC change
They work well and apart for allowing for correctly staged certification, also ensure that tasks are carried out in the correct order (rather than from memory etc)
Examples include:
Engine change
APU change
FFG/MEC change
They work well and apart for allowing for correctly staged certification, also ensure that tasks are carried out in the correct order (rather than from memory etc)
Not surprisingly they are regularly reviewed by office staff and any changes announced to all. The forms are printed from the company intranet to ensure the latest version is always used.
Bear in mind you cant rely on AMM for dupes. EASA and FAA run slightly different schemes for this then outside these individual authorities have different systems. So unless you paid Boeing/Airbus etc for a customised AMM for each authority.......
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EASA: Any update of a task card e.g PDI, Transit, Daily check or engine change etc would be reflected on the new issue no. and new date. Subsequently, a LAE should annotate that clearly in a T/L entry.
QA and Tech Record duties are to enforce updated copies are distributed to all concerned and old copies destroyed.
QA and Tech Record duties are to enforce updated copies are distributed to all concerned and old copies destroyed.
