Defects, Maintenance Releases and Schedule 5

[blackhand]

Leadsled noted on the Barrier thread..

... Sadly, many GA tyres are thrown away with life remaining, at great expense, at an annual/100h inspection, because of a stupidity in Schedule 5. Serviceability of an aircraft tyre does not depend on the weather forecast for a flight. Tootle pip!!

The question is how much discretion does the workshop have in releasing a GA aircraft to service?

[Clearedtoreenter]

That's a VERY good question!

[tnuc]

Where does Schedule 5 say you have to throw servicable tyres away ?
My understanding is that the LAME inspects the tyres, if they are serviceable - i.e within manufacturers limits for use then they can remain in service.

In this case it is possible that tyres may be worn to a point that they only last a few Hrs beyond his inspection, but they can stay on the aircraf

In GA the responsibility then falls on the Registered Owner/Operator and Pilots daily inspections to pick find and take action if the tyres wear out and require replacing during the period the maintenance release is in force.

Unforunatly many Registered Owners/Operators during the validity of their Mainteance Release will ignore the now worn out tyre untill the next inspection. Whose fault is that ?

[Creampuff]

CAR 43(7) says:

(7) A maintenance release may be issued in respect of an aircraft only if:

(a) all maintenance in respect of the aircraft required to be carried out to comply with any requirement or condition imposed under these regulations has been certified, in accordance with regulation 42ZE or 42ZN, to have been completed; or

(b) [not relevant – SFP flight].

Bloggs the LAME has been asked to carry out a periodic inspection of an aircraft in accordance with Schedule 5 and issue an MR for it. Let’s keep it simple to start with, and ignore whether the aircraft is to be released to charter, aerial work or private operations.

Bloggs has just completed a thorough check of all items listed in Schedule 5, to determine whether those items will continue to be airworthy until the next periodic inspection due in 12 months or 110 TIS, whichever comes first, as well as a diligent review of all ADs applicable to an aircraft.

Let’s continue to keep it simple to start with, and assume that the only thing that worries Bloggs is the nosewheel tyre. Bloggs determines that the nosewheel tyre has (to use Leaddie’s words) ‘life remaining’, but Bloggs is concerned that the remaining life may be used up before the next periodic inspection will become due.

Bloggs conservatively judges that there are about 12 landings left in the tyre. Bloggs is confident that at least that number of landings will be carried out before the next periodic inspection.

Bloggs issues the MR with this entry in Part 1: “Nose wheel tyre to be replaced no later than 12 landings carried out after [date of issue of MR]”

What rule has Bloggs broken?

For those who point out that that the remaining tyre life could be wiped out in one, brakes-on landing, I note that precisely the same thing could happen even if Bloggs fitted a new tyre before releasing the aircraft. (That’s why there are rules about pre-flight inspections and recording of defects.)

Let’s add one small complication. Let’s assume Bloggs also puts this entry in Part 1: “Engine oil and oil filter change to be carried out no later than xxxx hours TTIS”. [xxxx is 50 hours after the TTIS when the MR was issued.] Bloggs adds that entry, because Bloggs determined from the approved maintenance data for the aircraft that the engine requires oil changes every 50 hours TIS.

What rule has Bloggs broken?

If it’s OK to issue an MR with an entry requiring an oil change before the next periodic inspection may fall due, why doesn’t the same concept apply to tyres with ‘life remaining’?

Let’s do blown nav light bulbs next….

PS: I agree, completely, with tnuc.

[LeadSled]

tnuc.
The point I was trying to make is that it is up to the LAME to determine that the aircraft will make it to the next annual/100h inspection ---- within the terms of para. 2.7 of Schedule 5 (If that is what you are using per. the Log Book Statement).

Many LAMEs I know, for PPP (Positive Posterior Protection) simply take the position that, if the tyres and brakes are new/overhauled, no AWI can have a go at them on those components.

In my view, the whole concept of the LAME being responsible (per. para. 2.7) for anything that is no longer under his control is quite wrong.

Once the aircraft leaves the hangar with its nice new, pristine and un-smudged MR, all bets are off, and the responsibility for the continued serviceability should fall to the registered owner, who does have control of the aircraft.

Tootle pip!!

[blackhand]

Creampuff, I am not sure there is a requirement to even enter it on the MR. If it passes serviceable criterea at the inspection it is fit for flight.
Lasting for the annual/100 hour period is, as you suggested, a very subjective matter.
My maintenance provider recently contacted me to let me know that the main tyre would probably only last til the 50 and to order a new one now, incidently 850 X 6 Dunlop @ $390 plus gst plus freight. No MR entry required as far as he was concerned- Aerial work by the way.

[Creampuff]

Folklore, Leaddie.

It's depressing that ostensibly intelligent people believe it and spread it.

So Leaddie, how do all those scared LAMEs protect themselves against the risk of engine failures after the MR has been issued? By your logic, 2.7 results in the LAME being responsible for an engine that fails 85 hours later, because everyone forgets to check and top up the oil during that period.

I'll have to think more about the scenario, BH. It seems to me that if the inspection determines that the inspected component may not remain airworthy until the next periodic inspection, the inspecting LAME should enter something on the MR.

[Mach E Avelli]

A pilot approved to update the GPS data base would enter the action in the MR and the calendar date of the next due update. As the MR could be valid for 12 months, there could be quite a few of these entries.
Now, question - if the aircraft runs past the due date of the next GPS update can it fly? Probably, but presumably an entry would then need to be made that the GPS was not to be used for navigation. Presumably, THAT particular entry would be made by a LAME. I know how it works in MEL - land, but this antiquated MR form that is still in use in GA is something else. Educate me.

[Creampuff]

In what classification of operation do you wish to engage the aircraft? Do you have to fly IFR? Is the GPS etc etc, down the list of 9 issues in the other thread. It always depends on the answer to each of the questions in that list.

If, for example, someone wants to operate the aircraft in day VFR aerial work, I don’t see what rule would prohibit that from happening, with an open entry on the MR: “GPS data base to be updated no later than [date X]”, beyond date X. I’ll have a think about it, but I anticipate that the rules would require a placard somewhere on the GPS display, stating that the data base is out of date.

[Old Akro]

Are you sure the early replacement of parts isn't profit driven and the regs used as the excuse?

[tnuc]

Common Sence must prevail. Its hard to understand LAMEs would be using the regs as an excuse to change tyres etc for a quick buck. Most GA types are in such a state of disrepair and are carrying so many defects that you don't have to look far to spend the $$ fixing actual defects.

[Mach E Avelli]

Getting back to the GPS data base example. "Common sense" tells me that an aircraft does not need this optional extra to fly either VFR or IFR, provided that the other equipment is sufficient to navigate with and the route does not require it.
But the words 'common sense' and 'legal" strike me as an oxymoron. Particularly with our fcuked up regulations. So, at database expiry date it becomes an open entry unless cleared by update or some other signature to continue without update? Yes? No?

[Creampuff]

Gosh MEA, you seem to be a little stressed.

If the MR has an entry that says: "GPS nav data base to be updated no later than 1 January 2013", and it's now past 1 January 2013, take 3 deep breaths and relax.

I'm good friends with people who would be happy to fly that aircraft, day VFR, with the entry still 'open' on the MR. I'm happy to sit in the back of the aircraft.

Those people regularly fly aircraft with a few entries open on the MR. Those people are also suspicious of MRs that have no entries. So am I.

[blackhand]

A MR release inspection is certified for and on behalf of a CAR 30 organisation.
The org issues the MR. AFAIK (disclaimer)

[baron_beeza]

I can't think of many organisations that would allow an aircraft to fly with an 'open' entry.

None I maintain, or fly, ever have. This is GA, charter, airline and military. (and in many countries at that).

I would get very nervous with any operator that tried that one on. Just my background and experience possibly....

I would be much happier with the PIC to endorse the entry with some closing action and stating how and why he is declaring the aircraft as serviceable.

[Creampuff]

We are therefore probably talking about different kinds of 'open' entries.

Let's assume an aircraft has 1,000 TTIS.

Its MR includes these endorsements:

- Engine oil and oil filter change to be carried out no later than 1050 TTIS.

- Pitot system leak check to be carried out no later than 1050 TTIS.

- Left hand nav light bulb blown.

Which of the open entries, precisely, are you worried about?

[Frank Arouet]

Get real Creampuff;

We argued this ad nauseum when you "lost" my evidence.

Common sense goes out the window when nepotism is the order of the day.

We discussed the problem with schedule 4 and found that the aircraft was only serviceable at the time of inspection. There was no warranty of fitness expressed or implied about what would happen in the legal "forseability" over the course of the next 100 hours/ 12 months.

Your lot put to evidence my gripe was with the engineer, however, being mates of mates, and as I didn't order the MR, the onus of the engineers resonsibility was to the vendor who did the dodgy MR.

BTW: where are my fabric samples, the propeller bracket, the rusted fuselage tubes, the documetation that had the A/C immersed in salt water in NG, the rivets that fell out of the starboard wing, the fuel injectors, etc. etc. which I still have details on hard paperwork.

My Act of Grace payment was via Dept of Finance, (Slipper of all people), and CAsA have never admitted liability in any way shape or form.

Don't preach on this forum about leagalise.

Ring me. If I'm sober I may talk to you, or you can make an appointment via the PM system. Otherwise keep your pompous pious ridicule to yourself until we have at least 20 beers at the Wig and Pen where we will be on equal terms.

Fcuk me mate!

PS. Stay out of this Blackfinger.

[Ixixly]

With the GPS's i've had in GA so far, any that never had their databases updated (Which was most as honestly it wasn't really necessary and we never had any problems) were placarded as being "DAY VFR ONLY" or something to that effect on them or in the case of the Bendix Kings used in Airvans it was actually a message on startup that it was for VFR use only. I should mention that these ones were of course installed in the Aircraft not handheld.

Mach E Avelli, in the only Aircraft i've flown IFR that had a GPS, we regularly did the update, can't remember anyone having to be specifically trained or approved for it, of course we were shown how to use the Garmin Update Program beforehand and it was often flown out-of-date on VFR operations, not IFR, sometimes it would just be busy or end up away from base for a few days and go out of date. I can't remember the MR ever having any entries related to the GPS being updated, that info was kept on a board in the Chief Pilots office and as usual Pilots required to check before flight, both board and GPS, never had CASA say anything about this to us.

[Progressive]

Use of the maintenance release

The level of confusion that abounds around the maintenance release astounds me given the relatively simple nature of the form and the availability of a CAAP (43.1) explaining its use.
Firstly there is nothing to prevent open entries on the MR past the 100 hourly inspection (as per the oil change mentioned above). The purpose of an MR is to record which maintenance will be due before the next major inspection. In the case of open entries which effect the operational status of the aircraft (EG: IFR orVFR) the CAAP gives clear instructions on how it should be endorsed to restrict this operation.

As for the LAME's liability to ensure continued operation until the next major inspection this is not strictly true. Under the CAR's and CASR's A LAME is held responsible for a part until it is "Repaired, replaced or inspected" thus the tire mentioned above could be legally released as serviceable for as little as one flight with the LAME absolved of responsibility for it after the first pre-flight inspection.

As for the LAME changing your tire "prematurely" this is always a cost benefit analysis between changing a tire during the 100 hourly (wheels already off to grease the bearings but wasting some tire life) and bringing the aircraft back to do the wheel change a few flight s later (additional down time and labor). In reality the additional cost of he later wheel change is going to be about an hours labor ($90) to jack the aircraft remove the wheel and re-fit it. Since this is 1/3 of the cost of the tire running the extra 12 landings you mentioned is COSTING money.

As for the old wives tale that an MR endorsement grounds the aircraft this is not strictly true. The purpose of an endorsement in part 2 of the MR is to notify the C of R holder or anyone likely to fly the aircraft that a defect exists in order for them to make an informed decision as to if the aircraft is serviceable. There is provision in the regs to make a specific statement to the effect that the aircraft is unsafe to fly in this part, but unless this statement is written it is up to the pilot. The above CAAP also provides provision to carry these defects forward beyond the 100 hourly so cosmetic defects flagged on the MR do not necessarily need to be repaired.

I also not on other threads the statement "defects from part two of the MR are transferred to part 1), this is incorrect. Part one of the MR is for recording known required maintenance which must be complied with before flight. Part 2 is for recording defects which occur between inspections. A brief reading of the notes below part two will show that defects entered in part two of the MR can be certified for directly in part two. Preferably with an entry in the log book as well.

[CHAIRMAN]

Bloggs has just completed a thorough check of all items listed in Schedule 5, to determine whether those items will continue to be airworthy until the next periodic inspection due in 12 months or 110 TIS, whichever comes first, as well as a diligent review of all ADs applicable to an aircraft.

Hey Creamie, how come the 110hrs if the MR states that MR is valid for 1 year or 100 hrs from the last one?