AD-ENG-4 under attack.

[Creampuff]

Bob: I've read your most recent post four times, slept on it, read it again, stone cold sober, drunk, then hung over, and I am still b*ggered if I know what you meant!

Everyone, I must be missing something that is obvious to others.
Schedule 5 says this, under the heading 'Section 2 The Engine':

(1) Check the external and internal required placards.
Note Reference should be made to the aircraft flight manual and airworthiness directives for the required placards.
(2) Take the following action in relation to the cowls:
(a) remove, clean and inspect the cowls, cowl flaps and fastenings.
(3) Inspect, and record the compression of, each cylinder.
(4) Take the following action in relation to the engine oil system:
(a) drain the sump or tank and refit the plug and lockwire;
(b) drain the oil cooler and refit and secure the hose;
(c) either:
(i) remove, inspect, clean and refit the pressure filter and lockwire; or
(ii) remove, open and inspect the cartridge full flow filter and fit a new cartridge and lockwire;
(d) inspect the oil cooler, oil temperature control valves, oil tank and attachment fittings;
(e) inspect all oil lines, fittings, breather pipe and the oil cooler shutter;
(f) refill the sump or tank with the recommended grade and quantity of oil.
(5) Take the following action in relation to the ignition system:
(a) remove the spark plugs, clean and inspect them, check the spark plug electrode gap, test the spark plugs and renew them if required;
(b) inspect the spark plug high tension leads and ceramics;
(c) inspect the magneto housing;
(d) inspect the breaker compartment and cam follower;
(e) inspect the breaker points for serviceability and check the breaker points gap, magneto engine timing and synchronisation;
(f) inspect the switch and earth leads;
(g) refit and torque the spark plugs;
(h) refit the spark plug high tension leads.
(6) Take the following action in relation to the fuel system:
(a) place the fuel selector in the off position;
(b) remove, inspect, clean and refit the fuel strainers and screens and lockwire;
(c) drain and flush the carburettor fuel bowl and refit the plug and lockwire;
(d) inspect the carburettor or fuel injection components;
(e) inspect the throttle and mixture shafts;
(f) inspect all fuel lines and fittings;
(g) move the fuel selector from the off position;
(h) inspect the auxiliary fuel pump for operation;
(j) pressurise and purge the fuel system and inspect it for leaks.
(7) Take the following action in relation to the induction system:
(a) remove the air filters, clean them, inspect them and refit or renew them;
(b) inspect the hot and alternate air systems for the integrity of seals and for serviceability of valves, shafts, bearings, magnets and hinges;
(c) inspect the induction manifold and hoses.
(8) Take the following action in relation to the exhaust system:
(a) inspect the exhaust system;
(b) remove the muffler shroud, inspect the muffler and refit the shroud;
(c) inspect the muffler internally for security of baffle cones;
(d) inspect the cabin heat flexible hoses.
(9) Take the following action in relation to the engine cylinders and baffles:
(a) inspect the cylinder assemblies;
(b) inspect the cylinder base to the crankcase area;
(c) inspect the rocker covers;
(d) inspect the push rod housing seals.
(10) Take the following action in relation to the crankcase, accessory housing and firewall:
(a) inspect the engine for evidence of oil leakage;
(b) inspect the accessories and drive belts;
(c) inspect the engine mounts and engine mountbolts;
(d) inspect the engine mount frame;
(e) inspect the firewall, including seals and sealant.
(11) Inspect the following controls for full and free movement in the correct sense:
(a) throttle, mixture and propeller;
(b) alternate air and carburettor heat;
(c) engine bay fuel strainer controls;
(d) oil cooler shutter and cowl flap;
(e) turbocharger.
(12) Take the following action in relation to the propeller:
(a) inspect the propeller for static track;
(b) inspect the propeller hub, spinner and backplate;
(c) inspect the wooden propeller attachment bolts;
(d) inspect the blades;
(e) inspect the counterweights;
(f) lubricate the propeller hub;
(g) service the propeller hub with air.
(13) Take the following action in relation to the turbocharger:
(a) remove the heat shield and inspect the turbocharger housing for cracks and oil leaks from the inlet and outlet ports;
(b) inspect the compressor and turbine wheel;
(c) inspect the rotating assembly bearing for end float;
(d) inspect the turbocharger mount;
(e) inspect the transition assembly, the induction and exhaust components and the clamps;
(f) inspect the upper deck pressure manifold and hoses;
(g) lubricate the waste gate linkages and the butterfly valve;
(h) inspect the flexible oil lines;
(j) inspect the controllers and actuators;
(k) inspect the compressor by-pass door;
(m) refit the heat shield.
(14) Take the following action in relation to the refitting of the cowls:
(a) check that no tooling, rags or other foreign objects remain in the compartment;
(b) inspect the latches and fasteners for correct tension;
(c) inspect the inlet and cooling air ducting;
(d) inspect the landing and taxi light wiring;
(e) inspect the cowl flap linkage and engine drain lines.
(15) Chock the wheels and check the brake operation, then set the park brake, start the engine and take the following action to determine satisfactory performance in accordance with the manuracturer's recommendations:
(a) stabilise the engine temperatures and pressures;
(b) check the idle speed, mixture and the magneto switch operation at low engine revolutions per minute;
(c) check the carburettor heat or alternate air operation;
(d) check the gyro or vacuum pressure indication;
(e) inspect the generator or alternator;
(f) check any unusual engine vibration or noises;
(g) check the engine response to throttle application;
(h) check each magneto and propeller governor for operation;
(j) check the static engine revolutions per minute, manifold pressure and fuel flow;
(k) check the idle cut-off operation.
(16) After taking the action described above, remove the cowls, inspect the engine for oil, fuel or other fluid leaks, then replace the cowls.

I say again, 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]

How would revocation of AD/ENG/4 increase the amount or frequency of engine maintenance required by Schedule 5, when AD/ENG/4, in its terms, imposes requirements in addition to those in Schedule 5?

Does anyone believe that AD/ENG/4 replaces the requirements in Schedule 5, despite what AD/ENG/4 actually says?

[Bob Murphie]

I didn't say AD/ENG/4 replaces the requirements on schedule 5, I am saying the AD is in addition to schedule 5 if you want to keep flying the aircraft with an "on condition" engine.

Schedule 5 in itself does not (and I may have to have a drink myself to get focused here), give any extension to manufacturers "hard time" recommendations, AD/ENG/4 does that. Doesn't it?

What does appendix A say?

[Creampuff]

Appendix A looks to me like a list of requirements, and when to do them.

AD/ENG/4 Amdt 10 Piston Engine Condition Check 12/2006

Appendix A

Requirement A1:
Carry out an engine performance run to determine the engine performance in accordance with approved data.
For turbocharged / supercharged engines, the output parameters shall be adjusted in accordance with manufacturer’s data.
Record engine and aircraft details and parameters achieved during the engine run on “Piston Engine Condition Report” (CASA Form 728) or an equivalent form. All completed forms shall be part of the engine maintenance record.
Note A1: Where possible, maximum RPM is to be attained with the aircraft stationary. However, where the aircraft manufacturer details in approved maintenance data that maximum RPM can only be achieved during take-off or climb, or the aircraft type does not permit maximum RPM to be safely obtained whilst the aircraft is stationary, an entry on the aircraft maintenance release by the pilot in command of the maximum RPM during the last flight prior to the periodic engine inspection is acceptable data.
Engine run parameters to be recorded include:
a. Take-off power
Take-off power shall be:
i. For a fixed pitch propeller aircraft - static RPM.
ii. For a constant speed propeller, normally aspirated engine aircraft, take-off power shall be maximum RPM at a manifold pressure, not less than 2” of static manifold pressure.
iii. For a turbocharged/supercharged engine aircraft, take-off power shall be maximum RPM at the manifold pressure detailed in the aircraft flight manual.
b. With the engine at operating temperature
i. Oil pressure at idle and at take-off power.
ii. Oil temperature at idle and at take-off power.
iii. Cylinder head or exhaust gas temperature at take-off power.
iv. Fuel pressure/flow at take-off power.
v. Ambient temperature and location altitude.
Requirement A2:
Carry out a cylinder leak check in accordance with:
a. The procedure(s) published by the engine manufacturer; or
b. In accordance with CASA AAC 6-32, where data from the engine manufacturer is not available.
Record the results of each cylinder leak check and / or inspection in the engine logbook.
Requirement A3:
A3(a) Oil change
Replace the engine oil and engine oil filter. Engine oil and the engine oil filter replacement in the period between the aircraft periodic inspections may be carried out by a pilot, other than a student pilot. CAR 42ZC (4) and Schedule 8 refers.
A3(b) Engine oil filter, oil pressure screen and suction screen inspection
All engine oil and engine oil filter replacements, including those carried out in the period between the aircraft periodic inspections, unless carried out by a pilot, shall include inspecting the engine oil pressure filter, oil pressure screen and, if applicable, the oil suction screen, for evidence of metallic particles, shavings or flakes. Take corrective action, where necessary.
A3(c) Engine oil uplifts
Record all oil uplifts. Review oil uplift records and take corrective actions, where necessary.
Requirement A4:
Review all data recorded per Requirement A1, A2 and A3 of this Appendix in order to assess the engine condition.
Note A2: Engines that fail the condition check per this Appendix even after defect rectifications per the manufacturer’s recommendations are to be overhauled. Only airworthy engines (see definition) are to be placed in service.
Note A3: AWB 85-4 “Aircraft Piston Engine Calendar Time Overhaul” provides guidelines for additional inspections related to the calendar time overhaul.
Compliance:
Requirement A1 - At each aircraft periodic inspection.
Requirement A2 - At the intervals not exceeding 100 hours with a planning tolerance of plus or minus 10 hours.
Requirement A3(a) - At intervals as published by the engine manufacturer with a planning tolerance of plus or minus 10%.
Requirement A3(b) - At each oil change and oil filter replacement, if applicable.
Requirement A3(c) - At each oil uplift.
Requirement A4 - At each aircraft periodic inspection.

Given what the AD says, the outcome seems to be that if you have elected to use Schedule 5 as the maintenance schedule for a private aircraft, you must do all of the stuff in Schedule 5, when required by Schedule 5, plus all the stuff in Appendix A to the AD, when required by the AD.

I'm still not getting it, and I'm sure there are LAMEs out there who know this stuff backwards.

If we revoke the AD and those additional requirements in Appendix A go away, how does that result in any more, or more frequent, maintenance having to be done on the engine in a private aircraft? Bushy? Trash Hauler?

[jakessalvage]

view from way out left

Not trying to disagree with any of the views people are putting forward. There's 3 sides to every story depending on where in the aviation spectrum you fit. As a LAME my concern with AD/ENG/4 is not the maintenance requirements but the shift in responsibility to the LAME/CAR 30. Here's my logic and I'll apologize in advance if it offends anyone.
First I think its important to understand that an engine that has not exceeded the manufacturers TBO in hours or calender time is operated condition monitored. If at the first filter inspection we find lots of shiny fragments we don't continue it in operation up to the recommended TBO just because its time in service hasn't been reached.
All manner of circumstances may arise during the life of an engine that would require it to be removed from service for repair and returned to service in accordance with the manufacturers recommendations.
The issue when operating beyond the recommended TBO is the continued airworthiness is not in accordance with the manufacturers instructions. Nor is continued operation beyond the manufacturers TBO approved by the country of origin airworthiness authority except for aircraft and engines operated in that state.
Therefore it would seem to me CASA have attempted to add a valuable tool for aircraft owners to allow for operation of an engine beyond the recommended TBO and still provide some continued airworthiness guidelines not approved anywhere else. In trying to do this noble act I believe they have inadvertently shifted the responsibility for continued airworthiness from the certificate of registration holder to the LAME's employer or CAR 30 certificate holder by some poor wording in relation to Schedule 5 and the AD itself.
Here's the really offensive bit, my opinion is that the CofR holder is the only benefactor in the TBO extension cycle, therefore the CofR holder should simply add to their log book statement how an engine is to be maintained if operation beyond the manufacturers TBO is to occur. The AD/ENG/4 should be revoked and rebranded as either an AWB or AC describing a method acceptable to the director how/when/why/etc an engine may be operated beyond the manufacturers TBO for Private and Aerial Work ops.
I also think a law should be passed to stop the abuse of the term on-condition. A component is either condition monitored or its fit and forget, unfortunately most GA owners believe operation of an engine beyond the manufacturers TBO is fit and forget, claims of if it ain't broke don't fix it are illustrations of this.
Maintenance regimes that have correctly identified and maintained components on-condition do so with a maintenance program that normally always increases in testing requirements as time in service increases and also reduces service limits as time in service increases. CASA Schedule 5 and AD/ENG/4 are not individually or combined a maintenance program.
In addition to my proposal I would also outlaw continued operation beyond the manufacturers TBO when the CofR holder changes. The logic is that a diligent operator who has experience and practices that enhance the life performance of an engine is unique and it should not be right that the next owner be allowed to continue the TBO extension. Again this could form part of an AWB or AC, not a rule or AD, CASA are not field/real world savvy enough to do this in any other way in my opinion.
Lastly, I think the idea of using statistics obtained via the CASA defect reporting system as a basis of whether operation beyond the manufacturers TBO is dangerous or not cannot be relied on. Hands up all the Cof R holders who report all the defects on their aircraft. Until this system records 100% of events at best information obtained can at best be described as ,..........interesting, perhaps my own experience are clouding my judgement of this and other issues.
Jake

[Spotlight]

Very cogent and very convincing Jake. As you say there are three sides to every story.

Its not unknown for CofR holders to take their business over the road under the current understanding of the A.D.

[Creampuff]

Thanks Jake

I am intrigued by your statement that:

… it would seem to me CASA have attempted to add a valuable tool for aircraft owners to allow for operation of an engine beyond the recommended TBO and still provide some continued airworthiness guidelines not approved anywhere else.

I'm still not getting the link between a manufacturer's recommended TBO - a when requirement - and Schedule 5, which, along with applicable ADs, impose the 'when' requirements for the purposes of aircraft whose CofR holders have elected to use Schedule 5 as the aircraft's maintenance schedule.

Perhaps people believe that irrespective of what Schedule 5 says, failure to comply with the manufacturer's recommended TBO may have liability consequences. That belief may be entirely reasonable.

However, I don't see how AD/ENG/4 negates the risk of liability for non-compliance with the manufacturer's recommended TBO.

AD/ENG/4 does not say: "If you do all of these things in addition to the things in Schedule 5, you don't have to do an overhaul when recommended by the manufacturer and you will have no liability for the consequences of not having done the overhaul."

AD/ENG/4 effectively just says: "Do all these things in addition to the things in Schedule 5."

I'd welcome (sensible) completions to these sentences:

(1) Before AD/ENG/4, I was obliged to do an overhaul when recommended by the manufacturer, because ……..

(2) After AD/ENG/4, I am not obliged to do an overhaul when recommended by the manufacturer, because ………

[Bob Murphie]

Jake Quotes: "The issue when operating beyond the recommended TBO is the continued airworthiness is not in accordance with the manufacturers instructions. Nor is continued operation beyond the manufacturers TBO approved by the country of origin airworthiness authority except for aircraft and engines operated in that state".

Which is what AD/ENG/4 addresses in Australia, no?

"Therefore it would seem to me CASA have attempted to add a valuable tool for aircraft owners to allow for operation of an engine beyond the recommended TBO and still provide some continued airworthiness guidelines not approved anywhere else".

Please forgive my quoting out of sequence. Your recommendations should be noted, but I should add that most aircraft C of R holders/ Owners are not qualified nor taught to interpret aircraft or engine log books, nor qualified to direct maintenance or recommend alterations to manufacturers TBO.

One should leave that to the experts who should be reasonably responsible for the work they sign out.

Sorry creampuff, we crossed posts.

[tnuc]

One Issue I have with engines in Pvt/Airwork remaining in service beyond MFRs recomended times is that there is no method in the system to notify the pilot(s) that the engine is operating "beyond" what the MFR says. Not a big deal for privatly owned one owner driver machines, but for aircraft that are hired or used as trainers There should at least be a requirment to put a placard on the aircraft or a note on the MR staing that the engine is beyond Rec TBO, so that persons "hiring" or training in aircraft who dont have access to the log books are advised and can make their own educated decision if they want to fly the aircraft.
If i went to a school to do some training or was to hire for a trip and was paying "top dollar" to use an aircraft i would expect that all systems would be operational and within mfr's limits, if an engine for instance where beyond tbo then i would either not use the aircraft OR would not expect to pay "top dollar" for the privlage of being the test pilot.

Case in point i was at a training org recently and noted that ALL (not some) of their aircraft had engines beyond TBO,for example a B58 with one engine 250 the other 450 over !
Now if the engines are maintained properly there is no reason to think that they are about to give up, (although i didnt see a chrystal ball on the mechanics desk) but to charge the aircraft ot at the full price others are charging for aircraft all within TBO are is a bit hard...

[T28D]

tnuc, how about reading the M/R where it says airwork only AD eng 4/7

[Creampuff]

T28D: You realise, of course, that Amdt 7 has been revoked?

I'd still welcome (sensible) completions to these sentences:

(1) Before AD/ENG/4, I was obliged to do an overhaul when recommended by the manufacturer, because ……..

(2) After AD/ENG/4, I am not obliged to do an overhaul when recommended by the manufacturer, because ………

[LeadSled]

Folks,

Over the years, DCA/DoA/DoT-ATG/CAA/CASA (not certain whether that is comprehensive and in the right order) have had various ways of expressing Australian unique mandatory life limits for engines. My memory tells me the first lists I saw were in the ANO 100 series.

For (essentially) AOC operators, we also have regulatory provision for engine life extension programs, with such as the TIO-540 running up to 2600 hours, well beyond manufacturer's recommended TBO., regularly and reliably.

Until AD/ENG/4, Am.7, there was no practical provision for private and aerial work engines to do the same thing, despite the "rest of the world".

In the best of Australian aeronautical tradition, there was immediate and very noisy objection to the change, with the usual forecasts of death and destruction raining from the sky, including various insurance company "technical experts" ie ex-LAMEs who objected to anything other than what they grew up with!

Prior to AD/ENG/4, Am.7, I regularly came across some really rough engines, but nobody would spend more than the minimum, because they were "close to overhaul". I am of the opinion that AD/ENG/4, Am. 7 and on has resulted in a significant improvement in the airworthiness of GA engines.

I still come across rough engines, but invariably with an AOC operator who has no life extension program, and is only interested in making "TBO" at the minimum expense. Who can blame them, with CASA making it increasingly difficult to establish or maintain an engine life extension program for "commercial" engines.

I am aware of engines in Australian flying schools running up to 3400 hours between overhauls. In the '60's, in UK "we" ran O/IO-540 over 3000 hours, with a couple of light tops.

If you want to know an FAA Part 135 operator's (roughly equivalent of our charter) engine life limits, you need to look at the individual operator's FAA Operations Specification, it will not necessarily be manufacturer's recommended TBO.

Tootle pip!!

[Bob Murphie]

Creampuff;

(1 Before AD/ENG/4, in AUSTRALIA, I was obliged to do an overhaul when recommended by the manufacturer, because there was no provision to do otherwise.


(2) After AD/ENG/4, and for AWK operations, I am not obliged to do an overhaul when recommended by the manufacturer, because any continued operation beyond the manufacturers TBO, (only approved by the country of origin airworthiness authority), did not apply to AUSTRALIA but thanks to AD/ENG/4 this is now possible.

In light of an earlier post, I can only emphasize that the average pilot / owner /operator is not qualified to interpret log books nor audit them sufficiently to able to supervise a maintenance regime other than that suggested by the LAME and schedule 5 and AD/ENG/4 (and it’s amendments), nor are some even qualified to read and interpret a maintenance release.

[jakessalvage]

there's hope

Hi again

Like most respondents I would like to see engine operation beyond the manufacturers TBO allowed in some format if its not going to be AD/ENG/4 current amendment.
My customers would all agree to a few more guidelines if they were based on real world experiences. For example an engine say used in mustering ops doing 400+ hrs a year has a much better chance of achieving high time in service than a private owners aircraft near the coast doing 30hrs annually.
I see nothing wrong with establishing guidelines for annual utilization or for the frequency of oil/filter changes and component inspection/testing. There may be other criteria as well.
As previously stated, each operator having discussed the process with their LAME long before the overhaul time comes due should include their system on the log book statement.
How about anyone who's interested, contribute their ideas for a better AD/ENG/4, post them here. Sorry I just don't accept the current wording or implementation of this AD is delivering the correct intent or the correct outcomes.
I've never seen or heard of an engine beyond TBO failing, not one, again I am suspicious of the reporting system not that the event has actually occurred. I have removed from service several engines beyond TBO for excessive metal production, excessive oil leaks (cracked cases), and failure to perform on ground runs. I've also had customers take aircraft elsewhere and continue the engine operation when I've thought they shouldn't. To the best of my knowledge none of these ended in in-flight failures. I guess I don't always get it right but I don't mind when the reasons are sound at the time.
I'm also surprised at the differing opinions on this thread all derived from the same legislation. Surely if you were the regulator you'd want everyone understanding the requirements better. Less money on lawyers and more on educators would be appreciated. I'd also challenge industry groups to do more eduction and less grandstanding.
Jake

[Creampuff]

Lots of words, but not quite the precision I was after.

there was an inconsequetial regulation that said arbitary TBO's set by arsecovering and money grabbing manufacturers meant I had to overhaul a perfectly serviceable engine that in all probability was less likey to fail than an brand new engine out of the factory

Which ‘inconsequential regulation’ was that, clearedtoreenter (regulation number please)? Perhaps it was somewhere in the:

ANO 100 series

Anything specific, Leaddy? Given your encyclopedic recollection of the rules, which one picked up manufacturer’s recommended TBO and made it mandatory in respect of private aircraft engines?

(1 Before AD/ENG/4, in AUSTRALIA, I was obliged to do an overhaul when recommended by the manufacturer, because there was no provision to do otherwise.

I apologise for appearing thick, and I don’t want to be tedious, but what, precisely was the legal link between the manufacturer’s recommended TBO and ‘when’ legal obligations in Australia, and how does AD/ENG/4 sever that link?

I have a strong, uneasy feeling that the belief that compliance with the manufacturer’s recommended TBO was a regulatory requirement, was folklore (happy to be proved wrong – regulation/ANO/CAO number please), or based on a belief about that most bandied about legal term ‘duty of care’ (oooh eeerrr!). In either case, I have a strong, uneasy feeling that it’s folklore that AD/ENG/4, in or of itself, revoked the regulatory requirement (if there was one), or ousted, entirely, all ‘when’ requirements imposed as a consequence of a common law duty of care and manufacturer’s recommendations.

[LeadSled]

Folks.

Anything specific, Leaddy? Given your encyclopedic recollection of the rules, which one picked up manufacturer’s recommended TBO and made it mandatory in respect of private aircraft engines?

I am actually going to see what I can find in old publications etc. Australia did not necessarily just follow manufacturer's recommendations, but published "Australian" life limits.

One I recall is that RR built 0-200's had a much shorter life than a Continental built engine that was nominally identical, from memory 800h v.1200h.

Others were below manufacturer's TBO, but an almost standard series of "100h extensions" usually took the life up to and beyond the said recommended TBO. At leasts in the GODs, there wasn't a swinging fee to apply for each extension, and a long delay for "permission".

Don't hold your breath, but if and when, I will put the references up here.

Tootle pip!!

[Creampuff]

So far in this thread, I've had at least 3 different versions of what the previous requirements were:

1 - the rules required me to do an overhaul when recommended by the manufacturer

2 - the rules specified when an overhaul had to be done, and that may or may not have been at the same time as recommended by the manufacturer (but extensions were granted as a matter of course - a bit like ANO/CAO 48?)

3 - there was no rule that said I was allowed to go beyond the manufacturer's recommend overhaul time, therefore I had to get the overhaul done when recommended the manufacturer.

I look forward to any primary references that support any one of these versions.

[LeadSled]

Folks,
Having consulted a few memories that are better than mine, I have come up with the following:

(1) In the 50's-early 60'2, DCA did a lot of monitoring of engine life, and actual condition at tear down for overhaul. The results were often a lot higher TBO than the then manufacturer's recommended TBO's.

(2) At that time, the Australian TBOs were published (as far as any of us can remember) in ANO 100 or 101.

(3) For reason's nobody really understands, in the mid/late 60's, the method of publication of the Australian TBO became an AD, and the processes for applying for extensions was elsewhere in the regulations. The engine monitoring and life extension programs were well understood by all, and in no way reminiscent of CAO 48 "standard exemptions".

(4) This applied to all engines, it did not differentiate between private, aerial work and charter/RPT.

(5) As Pilykism started to permeate (by now) CAA, the form of the AD (and regulations elsewhere related to extensions) changed, and became AD/ENG/4 for piston engine.

As a note, this was the time of many helpful changes, including "major" being dropped from "major damage", without any consultation of consideration of the results for industry, and greatly increasing the cost of repairs to minor damage, eliminating the ability to do repairs per. FAA AC 43.13.

Some of you may also remember this is when we (those of us with subscriptions?) all got a second free CAR folder, with a happy little note to say this is where we could put all the greatly increased volume of regulations expected to be issued in the "near future". This about 1992.

(6) In 1995/96, AOPA (Dick Smith, President) started the push to get rid of Australian unique airworthiness standards, and Australian unique AD's, and to allow us the equivalent of US/Canada/UK/NZ/SA --- engines on condition for aerial work and private operations ---- not previously permitted in Australia.

That program was finally successful with AD/ENG/4, Am.7. for engines on condition. The rest of the program to get rid of unique Australia ADs has waxed and waned, but once CASR Part 139 went into place, many Australian ADs have been canceled.

CASR 21-35, going in place in 1998, virtually eliminated unique Australian certification standards, but we still have a swag of AD/GEN/ that were/are redundant.

But, after all, this is Australia, and instead of getting rid of all the redundant little "Australianism's", all the "usual suspects" want to put them in CASR Part 90 --Additional Airworthiness Requirements.

Under the present state of the rules, it would be quite feasible to cancel AD/ENG/4 ----IF, AND ONLY IF ---- a proper education program is put in place to get the message across to LAMEs, AWIs, and insurance companies that "recommended" means recommended, and an alternative is put in place to define life for charter/RPT engines. The latter preferably reinstating the well proved process for engine monitoring and life extension used safely and economically from the '40's through to the Rise of Pilyk.

Tootle pip!!

[Creampuff]

Such meandering imprecision is not quite what I’m after.

I find it utterly amazing that, notwithstanding the apparently expensive and unnecessary consequences of being obliged to perform an overhaul on a private aircraft engine when recommended by the manufacturer, no one can cite the regulation or order that imposed the obligation. All those aircraft owners and LAMEs out there who were struggling under the terrible burden of compliance with recommended overhaul periods for so long, and not one of them can cite the regulation or order that imposed the obligation?

Surely when the struggling CofR holder questioned the cost of and need for an overhaul on their smooth running engine, the LAME pointed to a dog-eared and grease-smeared regulation or Order, made by those terrible, aviation-hating CAA or CASA lawyers.

Surely? And surely such an important rule would be burned in their brains and recalled with ease. Surely?

My money’s still on folklore, but am happy to proved wrong with a regulation or order. My money’s on the propagation of a belief that, irrespective of what the rules did or did not require, the common law duty of care required compliance with manufacturer’s recommendations, and that AD/ENG/4 changed that. The first part may well be correct; good luck with the second!

[T28D]

Creampuff, I'm with you, notwithstanding the oblique nature of the regulations governing manufucurers recommendations, there is absolutely no need to mess about with AD eng 4/7 it works.

And the old sayling "If it ain't broke, don't fix it" is valid in this case.

The discussion re: regulation is academically good but it is just that, an academic exercise.

[Bob Murphie]

Yesterday I phoned a LAME who has done a lot of work for me. He stated that his Hangarkeepers Liability Insurance allows him a 25% over run on manufacturers TBO and zero on engines over 12 years of age.

He believes we only have the current AD to work from and doesn't remember the sequence of events but is of the opinion before AD/ENG/4 (7) engines were overhauled at manufacturers TBO. Extensions were applied for on an individual basis.

An Insurance spokesman said LAME's insurance was done on a case by case basis.