AD-ENG-4 under attack.

[tipsy2]

Creamy, actual prosecution MAY be avoided by the use of a threat (to prosecute). That is of course a sleazy cheats way of obtaining compliance that yes I have directly witnessed.

I took the appropriate action (and avoided any involvement of the legal fraternity) under the circumstances and then had the particular officer 'removed'.

No names or the circumstances will be mentioned, I still to this day cannot believe the pettiness and the ultimate stupidity of the officer concerned to have even embarked on the course he chose.

tipsy

[Bob Murphie]

Creampuff;

I say again, "COULD" is the operative word here in the AD/ENG/4 matter and LeadSled's illuminating highlights.

You are as aware as I, of what CASA "could" have done to save me bundles of money with regard para 2.7 but a lot ignored the FACT in the name of "cronyism".

A CASA counselling session does not, a safety redress make.

NOTE;

"The Commonwealth Ombudsman report concluded in recommendation 3: "CASA to consider the accuracy of its advice about the suitability of CAR Schedule 5 and:

(i) Take any necessary appropriate action and,

(ii) advise Mr Murphie of its final position in regard to CAR Schedule 5."

I am miffed about this miscarriage of ignored proceedure and It "COULD" have been addressed, and I still await CASA's response, but the maintenance releases are still being signed out with the corolory of a carbon copy of my near death experience.

But who cares, it's only administrative action?

[LeadSled]

Creamie, Old Mate,

Actually, in my case I have not one, but two W&B torque wrenches, and yes, they do have calibration certificates issued by a CASA approved org., plus gap guage, gap tool, thread cleaner and thread chaser, plus approved thread lube. Even a Champion socket and 12 pt. open ring spanners for the plug body and the proper fitting of the lead. And they go everywhere with me, along with the rest of the servicing (not a CASA approved term, it's all maintenance) kit.

How's that grab ya!!

And I will bet my "calibrated wrist" to produce 32-36 ft/lb. (see Wright/ Lycoming/ TCM Continental for correct data for engine type) against any LAME, but that is beside the point, I am unaware of any exemption to allow the use of 'calibrated wrists'.

Don't kid yourself about the "Magic of Maintenance", with few exceptions, CAR 3/FAR 23 aircraft are crude devices, with engines of about the sophistication of the Grey Fergi tractor, with one notable exception, at least the Fergi has got a manual spark advance.

As for battery maintenance, are you referring to open lead/acid, sealed lead acid, gel/cell or nickel/cadmium, I would be happy to supply you with the data, if you have a need. I use examples of each.

Ain't life grand!!

Tootle pip!!

[bushy]

Jiggery pokery

Most of the rules and regulations, maintenance schedules, orders, etc are really there to protect people who are not in the aeroplane. CASA is there to protect the government from any legal challenges arising from aviation.
There are many contradictions and vaguaries. CASA seems to have set itself up as the source of all knowledge, superior to all manufacturers and engineers.
CASA has decided that the PA32 must have wing spars replaced after 11000 flying hours. Nowhere else does this happen. Piper recommends an inspection at 70,000 hours (yes seventy thousand hours), and they have a scheme for this inspection. CASA will not even accept this Piper inspection scheme.
I have serious doubts as to CASA's motivation.

[Creampuff]

Oh I see, Leaddy.

You have and use:

W&B torque wrenches [that] have calibration certificates issued by a CASA approved org., plus gap guage, gap tool, thread cleaner and thread chaser, plus approved thread lube. Even a Champion socket and 12 pt. open ring spanners for the plug body and the proper fitting of the lead.

So when you said:

All you blokes and blokesses who routinely cleaned fouled plugs (a common enough byproduct of using 100LL in engines designed for 80/87) don't let me catch you using a Torque Wrench that doesn't have a current calibration test certificate ---- you all do use a torque wrench don't you?

you weren't actually suggesting that the requirement to use a calibrated torque wrench is silly and unnecessary.

You understand the intricacies of battery maintenance, so when you said:

As for that hardened criminal element in aviation, who use solar powered trickle chargers on parked aircraft, cease and desist, unless the said charger is "approved" and is only being used pursuant to a CAR 30 approval.

you weren't actually suggesting that there's no risk in trickle charging any battery for long periods.

I think I now know what you were trying to say ……. I think …. You weren't actually suggesting there's no valid technical basis for these requirements … were you?

By the way, how many people do you know who have been prosecuted for not using a calibrated torque wrench, or for using a solar trickle charger? As I said, the nearest 10 will do……

[LeadSled]

Creamie, Old Mate,

My personal position is: If you don't know how to do the job (and that includes the right data and appropriate tools) don't. If you have any doubts about your capability to do the job, don't. And if it is an aeroplane, not a motor car, make certain the MR or aircraft logs books correctly reflect what you have done, don't give CASA a free kick.

P7 is not confined to flight operations, for those of you who don't subscribe to P7, you should; Prior Planning Prevents Piss Poor Performance. Why's it called P7, I don't know, either, maybe the guy who invented it couldn't count, or maybe it should be Proper Prior etc., etc.

A comment on batteries: I personally don't like the idea of charging batteries in a stationary aeroplane, no matter how small the trickle, and no matter how smart the microprocessor program, even if FAA have no objection. I can't personally go along with the idea that there is not at least a small amount of some highly corrosive gas about, and it won't be carried away by the battery box vent.

The best place to charge a battery, clean it, dress the terminal and generally get rid of all the dirt and worse is clear of any machinery. There are some very good chargers available, but they do not include the $20-30 or so units from auto stores.

All the battery manufacturers we are interested in here have good web sites, getting "the acid" on good battery maintenance, and the right charger characteristics, are no further away than your computer.

As a matter of interest, some of the best chargers to meet the battery manufacturers recommendations for maintenance charging are in boat shops.

And, folks, please, please, please always wear good safety glasses when you are handling a battery, the liquid contents and your eyes mix all too well, to the very great detriment of your eyesight. Murphie's law is merciless.

Sadly, some of the worst examples of "assault n' battery" will be found in "fully approved CAR 30" hangars.

A bit of a long way from AD/ENG/4, but what the heck.

Tootle pip!!

[Creampuff]

I'll take that as a 'no' and 'zero', Leaddy!

To get the thread back on track, what will happen if AD-ENG-4 is revoked?

[Bob Murphie]

Creampuff;

I don't know where your question is leading because I figure (rightly or wrongly), that you are a closet "good guy" despite our being on the opposite sides of the fence at one time or another.

Murphie's Law is absolute, takes precedence over anything CASA office of Legal Counsel can come up with. I know I wrote the book and the amendments from personal experience.

Let me ask you this question;

What will happen if AD/ENG/4 is not revoked.

[Creampuff]

AD/ENG/4 Amendment 10 applies to piston-engined aircraft whose COR holders have elected to use Schedule 5. It says, against the 'Requirement' heading and 'For aircraft in Private operations and / or Aerial Work operations' subheading:

To ensure the continuing airworthiness of the engine, and those components necessary for the operation of the engine, in addition to the requirements of Schedule 5 of the Civil Aviation Regulations; carry out the maintenance actions detailed in Appendix A of this Airworthiness Directive (AD).

[bolding added]

That suggests AD/ENG/4 imposes requirements in addition to those in Schedule 5. It would seem to follow that if AD/ENG/4 were to be revoked, those additional requirements would cease to apply.

Perhaps people are concerned that if the additional requirements were to be revoked, they would be replaced by something more onerous. I have no insight into whether that would happen or, if so, what the requirements would be.

[Trash Hauler]

The way I see the situation is that CAR 41 requires that the maintenance schedule includes the provisions of maintenance for components. In the case of the engine this information is not contained in Schedule 5 therefore I am still required (as a LAME) to refer to manufactures data for the what, when, how for the engine and its sub-components.

As an AD can overrule the manufacturers data AD-ENG-4 provides alternate requirments that appear to me to be less onerous than the manufacturers data for an aircraft owner. A repeal of AD-ENG-4 would appear to lead to more onerous requirements.

But then again as a LAME at least I can sleep a bit better at night...........

[ForkTailedDrKiller]

A repeal of AD-ENG-4 would appear to lead to more onerous requirements.

That is my understanding!

The FTDK is due a 100 hrly - I expect it to be lenghty and expensive.

Dr

[Creampuff]

[Shakes head in continuing disbelief at the chronic incapacity of Australia to sort this sh*t out]

All, there’s a difference between:

when maintenance has to be done (e.g. annually)

what maintenance has to be done (e.g. replace spark plugs), and

how maintenance has to be done (e.g. using the toys Leaddy says he has, in accordance with the data Leaddy says he has).

The repeal of AD/ENG/4 cannot, in itself, have an effect on all 3, because AD/ENG/4 does not, in its terms, purport to codify all 3.

[Trash Hauler]

I think you lost me Creamy

[T28D]

We seem to have lost the fundamental fact that nothing is wrong with AD eng 4/7 IT Works and has done for a long time.

[Bob Murphie]

I'm a bit lost here as well Creampuff. But I'll be guided by your wisdom (to an extent).

Schedule 5 is a CASA aircraft inspection schedule, somewhat argueable it now seems for an aircraft. There is an AWB that purports to hold rank over the CASA schedule for maintenance of an aircraft and that the same persons argue makes the schedule redundant ????

AD/ENG/4 is an aircraft engine condition report that gives an on condition extension to the life of the aircraft engine, not the aircraft one imagines. To make this work, certain things (like oil uptake), need to be monitored over the course of the pre-periodical, (100 hours/ 12 months), and again subject to Private and AWK aircraft only.

AD/ENG/4 is not part of a schedule 5 inspection, but "additional" to it unless strict adherence to "hard time" engine data is applied, in which case most engines (ie over 12 years of age or say 2000 hours), would be subject to. ???

As I said before, if it were left alone and not meddled with, what would be the repercussions? Status quo or is there something sinister we don't know about.

If it were meddled with, what then?

Do we go back to prescriptive "hard time" at great cost to us "bottom feeders" or can CASA make it harder or easier?

I think any repeal of any matter should have in place a better replacement prior. This does not appear to have been thought out.

[Creampuff]

At present, CAR 41 says:

(1) The holder of the certificate of registration for a class B aircraft must ensure that all maintenance required to be carried out on the aircraft (including any aircraft components from time to time included in or fitted to the aircraft) by the aircraft's maintenance schedule is carried out when required by that schedule.

At present, CAR 42B says

(1) Subject to subregulation (2), if:

(a) the holder of the certificate of registration for a class B aircraft that is an aeroplane has elected to use the CASA maintenance schedule for the aircraft's maintenance; and

(b) the election is in force;

the aircraft's maintenance schedule is the CASA maintenance schedule.

(2) If:

(a) a person has elected to use the CASA maintenance schedule for an aircraft's maintenance; and

(b) a turbine engine is included in the aircraft;

all instructions issued by the manufacturer of the engine for the continued airworthiness of the engine are to be taken to form part of the CASA maintenance schedule and the election has effect accordingly.

So let's assume that we've got a bugsmasher that doesn't have a turbine engine, and the CofR holder had elected to use the CASA maintenance schedule for the aircraft's maintenance. That means the CofR holder must ensure that all maintenance required to be carried out on the aircraft (including any aircraft components from time to time included in or fitted to the aircraft) by Schedule 5 is carried out when required by Schedule 5, and, because the aircraft does not have a turbine engine, CAR 42B(2) does not deem the instructions issued by engine manufacturer to be part of Schedule 5.

Meanwhile, CAR 42V says:

(1)A person carrying out maintenance on an Australian aircraft must ensure that the maintenance is carried out in accordance with the applicable provisions of the aircraft's approved maintenance data.

CAR 2A defines 'approved maintenance data' to mean:

(1) Subject to subregulation (3), the approved maintenance data for an aircraft, aircraft component or aircraft material consists of the requirements, specifications and instructions that are:

(a) contained in the maintenance data set out in subregulation (2); and

(b) applicable to the maintenance of the aircraft, aircraft component or aircraft material, as the case requires.

(2) For the purposes of paragraph (1) (a), the maintenance data are:

(a) requirements in:

(i) regulations 42U, 42W, 42X, 42Y, 42Z and 42ZA or in instruments made under those regulations; and

(ii) directions (however described) made under an airworthiness directive or under regulation 25, 38 or 44;

being requirements that specify how maintenance on aircraft, aircraft components or aircraft materials is to be carried out; and

(b) specifications in documents or designs approved under regulations 22 or 35 by CASA or by authorised persons as to how maintenance on aircraft, aircraft components or aircraft materials is to be carried out; and

(c) instructions, issued by the manufacturers of aircraft, aircraft components or aircraft materials, that specify how maintenance on the aircraft, components or materials is to be carried out; and

(d) instructions, issued by the designers of modifications of aircraft or aircraft components, that specify how maintenance on the aircraft or components is to be carried out; and

(e) any other instructions, approved by CASA under subregulation (4) for the purposes of this paragraph, relating to how maintenance on aircraft, aircraft components or aircraft materials is to be carried out.

(3) CASA may, for the purpose of ensuring the safety of air navigation, declare in writing that an instruction mentioned in paragraph (2) (c) or (d) that CASA thinks is deficient is not included in the approved maintenance data for an aircraft, aircraft component or aircraft material.

(4) CASA may, for the purposes of paragraph (2) (e), approve instructions relating to how maintenance on aircraft, aircraft components or aircraft material is to be carried out.

[bolding added]

Can someone explain to me which addition to Schedule 5 requirements effected by AD/ENG/4 would, if removed, result in more, or more frequent, maintenance having to be done under Schedule 5, or otherwise, on a piston engine? For the purposes of the CARs, isn't all that 'approved maintenance data' about how maintenance is to be done, not when it is to be done?

Now, it may be that when AD/ENG/4 was originally made, something was taken out of Schedule 5 - I don't know. It may also be that part of the plan to revoke AD/ENG/4 (if - repeat if there is such a plan - I don't know) includes inserting something back into Schedule 5 or issuing a superseding AD - I don't know.

However, I don't understand how revoking an AD that, in its terms, imposes requirements in addition to Schedule 5 can, in or of itself, have the effect of either:

(1) adding requirements on top of those in Schedule 5, or

(2) creating or rejuvenating obligations under the CARs to doing something when specified by the engine manufacturer.

Serious questions Trash Hauler, as you're obviously having to deal with this stuff day-to-day:

(1) How do you 'join the dots' between the CAR 41 and an engine manufacturer's 'when' requirements, given that 'approved maintenance data' are, by definition, 'how' requirements, not 'when' requirements?

(2) Even if you can 'join the dots', how does the existence of AD/ENG/4 sever, entirely, the link to the engine manufacturer's 'when' requirements?

[Bob Murphie]

Thanks for wasting a heap of my time and others who come to the same conclusion that your post as definitive of "our" regulator, is the problem, not the solution to the dwindling GA scene.

Schedule 5 is in fact the manufacturers schedule whatever that may be?

Engines, except for the prescribed maintenance, in the schedule 5 do not confer any ability to extend the life above manufacturers recommendations of public liability except if you interpret the AWB as a biblical stone tablet that again makes schedule 5 redundant?

May I (in jest) suggest we go back to "major inspections" every 4 years and rip off all that Irish linen and replace at 4 yearly intervals with the same stuff and repeal the option of replacing it with Ceconite or Stitts.

[Chimbu chuckles]

At last a sensible post...certainly there are critical items like control lines, throttle cables etc that need to be changed out at regular intervals.

ENG 4 on the other hand is sensible because there is no evidence to suggest that time expired engines signed out under ENG 4 are any more likely to fail than any other engine. (Or is there?)

Not only is there NO evidence that engines operated sensibly and carefully, ie with good monitoring-both direct and periodic, beyond TBO are more prone to failure than those overhauled/replaced at TBO but there is plenty of evidence that engines just overhauled or new are more likely to fail.

The first 300 odd hours on a new/overhauled engine are significantly more risky from an engine failure point of view than the next 2000 hours.

[bushy]

yes

In 15,000 hours of flying the only engine failure due to mechanical failure I saw in an aeroplane I used to fly, happened to a new PA32 that had flown the pacific on it's delivery flight. It suffered a broken camshaft at 200 hours.
I did have two turbocharger failures which rendered the engine useless, but the engine was intact, and worked fine when the turbo was replaced.

[T28D]

Yup nothing wrong with AD eng 4/7 leave well enough alone, if it ain't broke , don't fix it !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! !!!!!!!!!!!