CAAP 215-1 (1)
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CAAP 215-1 (1)
Has any body yet come to grips with CAAP 215-1 (1) Guide to Preparation of Operations Manuals,which came into being last August? More importantly has CASA yet approved (OK accepted) an Ops Manual written to this CAAP?
Looks to be very ... comprehensive.
Looks to be very ... comprehensive.
Rgmb, you have hit the nail on the head. The time taken to aprove ops manuals and issue an AOC is abysmal, disheartening and killing general aviation.
Does anyone know anyone who has got an AOC in less than 12 months? 2 years seems to be the norm. How can this be good?
Does anyone know anyone who has got an AOC in less than 12 months? 2 years seems to be the norm. How can this be good?
Folks,
Just as well the big operators don't have to jump through the same hoops of fire that besets GA, the majors would never get airborne.
You would never believe that a CAAP is, more or less;"A way but not the only way to comply" when CAAPs are treated as if they were regulatory, just as MOSs are being treated as regulatory.
It seem the "compliance teams" can't figure out if a manual is compliant, unless it follows the CAAP word for word -- or they farm out assessment to a contractor --- anything but make a decision.
What is being demanded of checklists and QRHs is nothing short of dangerous, as well as ignoring CASR Part 21 and CAR 138.
Tootle pip!!
Just as well the big operators don't have to jump through the same hoops of fire that besets GA, the majors would never get airborne.
You would never believe that a CAAP is, more or less;"A way but not the only way to comply" when CAAPs are treated as if they were regulatory, just as MOSs are being treated as regulatory.
It seem the "compliance teams" can't figure out if a manual is compliant, unless it follows the CAAP word for word -- or they farm out assessment to a contractor --- anything but make a decision.
What is being demanded of checklists and QRHs is nothing short of dangerous, as well as ignoring CASR Part 21 and CAR 138.
Tootle pip!!
Last edited by LeadSled; 1st Feb 2013 at 13:19.
"A way but not the only way to comply"
2.5 For the purposes of subregulations 215 (3) and (6) of the Civil Aviation Regulations 1988, each operator must include in the operator’s operations manual so much of the information set out in CASA’s publication ‘Guide to the preparation of Operations Manuals’ that is relevant to the operator’s operations and must provide copies of the manual to all operating crew members employed by the operator.
In practice, we could do away with the CAAP and allow operators to determine a logical format for the OM based on their particular operation.
In the CAAP Headings appear more than once - Bird/animal and references to Annexes that do not exist.
CAR 138
Last edited by 601; 1st Feb 2013 at 20:23.
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I can assure you that even when you copy & paste word for word the CASA provided example for a DAMP manual, you get audited and a non conformance list of several things and a nasty letter threatening all sorts of things.
And, when you ask the audit guy can we just save the hassle and alter the document to your liking on the spot.....the answer is no. He has a process to follow
And then when you battle the Fing morons about it, you get nowhere. Guilty for doing the right thing the first time
No I am not making this up.
Creamie, and tell the good folk what you really think of CAAP's. I love your story on CAAP's
And, when you ask the audit guy can we just save the hassle and alter the document to your liking on the spot.....the answer is no. He has a process to follow
And then when you battle the Fing morons about it, you get nowhere. Guilty for doing the right thing the first time
No I am not making this up.
Creamie, and tell the good folk what you really think of CAAP's. I love your story on CAAP's
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I have no idea what you are talking about, Jaba.
I have never read a CAAP, and never intend doing so.
I therefore have no thoughts about them.
I have never read a CAAP, and never intend doing so.
I therefore have no thoughts about them.
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Agreed 601.
There is really only one way of achieving an 'accepted' operations manual. Write the manual to satisfy the Compliance Statement. That is what you'll be primarily audited on. Should also bear in mind that the Check & Training Manual is the only manual that is approved (where said company is seeking the liberties provided by CAR217). The rest, by and large, are 'accepted'. The catch however is that a compliance statement must be able to be satisfied from the contents of the manual. Obviously this is a simplistic explanation to a complex issue but may assist some in understanding the process.
D
There is really only one way of achieving an 'accepted' operations manual. Write the manual to satisfy the Compliance Statement. That is what you'll be primarily audited on. Should also bear in mind that the Check & Training Manual is the only manual that is approved (where said company is seeking the liberties provided by CAR217). The rest, by and large, are 'accepted'. The catch however is that a compliance statement must be able to be satisfied from the contents of the manual. Obviously this is a simplistic explanation to a complex issue but may assist some in understanding the process.
D
Last edited by Defenestrator; 2nd Feb 2013 at 11:55.
I can assure you that even when you copy & paste word for word the CASA provided example for a DAMP manual, you get audited and a non conformance list of several things and a nasty letter threatening all sorts of things.
And, when you ask the audit guy can we just save the hassle and alter the document to your liking on the spot.....the answer is no. He has a process to follow
And then when you battle the Fing morons about it, you get nowhere. Guilty for doing the right thing the first time
No I am not making this up.
And, when you ask the audit guy can we just save the hassle and alter the document to your liking on the spot.....the answer is no. He has a process to follow
And then when you battle the Fing morons about it, you get nowhere. Guilty for doing the right thing the first time
No I am not making this up.
Nobody who has any experience with Operations Manuals thinks you are, it really is a nightmare.
Blackhand,
It starts with how we now handle type acceptance, in Part 21, which is dependent on the state that did the original type certification -- we can't change to original certification standard at will. The AFM is part of the original type certification.
Part 138 is straightforward, it requires an Australian aircraft to be operated in compliance with the AFM.
It is a widespread practice for individuals in CASA to demand wholesale changes, particularly to AFM QRH and checklists.
As a matter of some interest, CASA is proposing that the complete Operations Manual for a Limited Category (21.189) be approved, not accepted, meaning what for CASA liability after an accident??
Tootle pip!!
What ever happened to CASA's effort back in 2006 when CASA purchased an OM that was to be used as "training manual" for FOIs.
Were there to many interpretations on "what," "how," "when," "why," "where," "responsibility," "targets," etc.?
As far as checklists go, there are three schools of thought within CASA at present. One requires strict compliance with the AFM checklist and the second requires starting from scratch and develop a flow. The third is a combination of the two.
What is CASA legal liability if they approve a checklist that is in a sequence that is different from the AFM.
If an accident occurs after using the CASA approved checklist, could a legal eagle argue that the flight was not conducted iaw the AFM?
The DAMP template is a crook. No templates for records etc. In the real world, if an operator was to use a manual template produced by the Authority auditing the legislation, only the in-house processes implementing the manual would need auditing. Training completed, records completed and available etc. - not the contents of the document. It should already meet the requirements.
Were there to many interpretations on "what," "how," "when," "why," "where," "responsibility," "targets," etc.?
As far as checklists go, there are three schools of thought within CASA at present. One requires strict compliance with the AFM checklist and the second requires starting from scratch and develop a flow. The third is a combination of the two.
What is CASA legal liability if they approve a checklist that is in a sequence that is different from the AFM.
If an accident occurs after using the CASA approved checklist, could a legal eagle argue that the flight was not conducted iaw the AFM?
The DAMP template is a crook. No templates for records etc. In the real world, if an operator was to use a manual template produced by the Authority auditing the legislation, only the in-house processes implementing the manual would need auditing. Training completed, records completed and available etc. - not the contents of the document. It should already meet the requirements.