Snag Sheets And Maintenance Releases, or "It always does that!"
Thread Starter
Nobody has mentioned "common sense". It's all very well 601 if you are operating RPT during business hours when a LAME is easy to access and I fully concur with your procedure under that condition.
Its a different matter at some airstrip in the bush miles from nowhere at 6.00 am on a Sunday morning.
Luckily for me, such a situation has never happened - yet. I have always had access to a LAME or a mobile phone to ring one and have dealt with very minor problems by following the LAMEs instructions which solved the problem. I'm not sure if that is legal but the issue was de minimis anyway.
Its a different matter at some airstrip in the bush miles from nowhere at 6.00 am on a Sunday morning.
Luckily for me, such a situation has never happened - yet. I have always had access to a LAME or a mobile phone to ring one and have dealt with very minor problems by following the LAMEs instructions which solved the problem. I'm not sure if that is legal but the issue was de minimis anyway.
Two examples of open endorsements
Permissible Unserviceability
Under CAR 37, a defect in, or damage to, an Australian aircraft can be approved as a PU subject to any condition(s) embodied in the approval. The aircraft still complies with the applicable type design standards and is considered airworthy.
Special Flight Permit
CASR 21.197, allows CASA or an authorised person to issue a special flight permit to a person for an aircraft, which cannot meet applicable airworthiness requirements and hence would otherwise be grounded.
http://www.casa.gov.au/mel_pu/031r03.pdf
RPT is not on my CV. but I have had defects on bush and remote strips.
Permissible Unserviceability
Under CAR 37, a defect in, or damage to, an Australian aircraft can be approved as a PU subject to any condition(s) embodied in the approval. The aircraft still complies with the applicable type design standards and is considered airworthy.
Special Flight Permit
CASR 21.197, allows CASA or an authorised person to issue a special flight permit to a person for an aircraft, which cannot meet applicable airworthiness requirements and hence would otherwise be grounded.
http://www.casa.gov.au/mel_pu/031r03.pdf
It's all very well 601 if you are operating RPT during business hours
Its a different matter at some airstrip in the bush miles from nowhere at 6.00 am on a Sunday morning.
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In the strictest terms (and according to a number of CASA FOI's and AWI's) anything that is not 100% completely in it's original serviceable state has to be endorsed on the MR. This includes a ripped seat cover, a wobbly glove box door, chipped paint or a broken map/reading light etc.
I know of an AWI that pinged a poor 300 hour pilot for having a ripped roof lining. It was not hanging down or obstructing the cabin, just a small rip probably cause by a fishing rod or something similar. The AWI made it very clear that it was a defect and needed to be endorsed on the MR.
Going by current trends, it would seem that if your aircraft is not in 'just out of the factory' condition then it must have defects. This standard is being set by CASA FOI's and AWI's all around Australia. Would bet anyone serious money that with this I could MR every aircraft in the country. The conspiracy theorist in me thinks that CASA is positioning itself and the regs in such a way that they could and can target anyone that gets in the way, i.e. making it technically impossible to comply with the regs.
Lets also not forget that if there is any open entry on the MR the aircraft can not fly, it is grounded. Why do people insist that a pilot can ignore a defect written on the MR?
Just to recap with a real world scenario: Your dropping some fishermen off to a remote fishing camp 400km from the nearest city, when one of your passengers rips the seat with the metal button on the back of his jeans as he climbs out of your 206/207/210. Your now grounded, its a defect. This defect needs to be endorsed on the MR and it needs to be cleared by an engineer or an OMEL. If thats not possible, you then have to get a flight permit from CASA to ferry the aircraft back to your maintenance base.
Good Luck!
I know of an AWI that pinged a poor 300 hour pilot for having a ripped roof lining. It was not hanging down or obstructing the cabin, just a small rip probably cause by a fishing rod or something similar. The AWI made it very clear that it was a defect and needed to be endorsed on the MR.
Going by current trends, it would seem that if your aircraft is not in 'just out of the factory' condition then it must have defects. This standard is being set by CASA FOI's and AWI's all around Australia. Would bet anyone serious money that with this I could MR every aircraft in the country. The conspiracy theorist in me thinks that CASA is positioning itself and the regs in such a way that they could and can target anyone that gets in the way, i.e. making it technically impossible to comply with the regs.
Lets also not forget that if there is any open entry on the MR the aircraft can not fly, it is grounded. Why do people insist that a pilot can ignore a defect written on the MR?
Just to recap with a real world scenario: Your dropping some fishermen off to a remote fishing camp 400km from the nearest city, when one of your passengers rips the seat with the metal button on the back of his jeans as he climbs out of your 206/207/210. Your now grounded, its a defect. This defect needs to be endorsed on the MR and it needs to be cleared by an engineer or an OMEL. If thats not possible, you then have to get a flight permit from CASA to ferry the aircraft back to your maintenance base.
Good Luck!
Thread Starter
Let's take this to reduction ad absurdam: scratched paint?
There is not one C172 that does not have torn interior trim, and I've never seen one with a TSOd cargo net.
There is not one C172 that does not have torn interior trim, and I've never seen one with a TSOd cargo net.
Last edited by Sunfish; 20th Mar 2013 at 10:32.
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It is pretty easy, if there is a defect that is not a show stopper you write NAD beside it.
For those of you unknowing or just sick of acronyms that means:
Non Airworthy Defect.
For those of you unknowing or just sick of acronyms that means:
Non Airworthy Defect.
When is a defect a defect? Read below and decide for yourself. Keep in mind the author of this CAIR report added his own comments as well as listing the numerous defects.
LOOKING UNDER THE CARPET.
From an old CAIR report:
I recently sat in the right hand seat of a Navajo engaged on a charter flight EN-Swan Hill-EN. The aircraft was based at Essendon. With several spare hours on the ground, and working on the adage “The Devil finds work for idle hands” I listed all the things wrong with that aircraft that could cause Human Factors problems particularly to an inexperienced IFR pilot, or a pilot not current on this particular aircraft. The maintenance release was squeaky clean of all endorsements and the aircraft had a shiny new paint job on the outside, but a diligent airworthiness inspector would surely have picked up the following on a ramp check – or maybe however, he would think it all too minor to worry about?
It took me only 15 minutes to find the following defects seen from a pilot’s point of view but almost one hour to write them down. Starting with:
1. A placard on the pilot’s side-consul states that the aircraft is limited to a maximum landing flap setting of 25 degrees. The Flight Manual has a similar notice with a requirement that 2 knots be added to the flight manual Vref speed for 40 flap when landing with 25 flap. The flap indicator shows a white sector band from up to 15 flap –and nothing else on the gauge to indicate exactly what flap setting in degrees is available beyond 15. When selecting the flap to down, the needle goes beyond 15 by ¾ inch into the unmarked areas and there is no indication if the flap micro-switch stops the flaps (via a limit switch) at 25 or 40. There is no external mark on the wings to indicate current flap position. This is common to many Navajos I have seen. In short, the flap indicator is misleading and impossible to comply with the flight manual restriction because there are no markings beyond 15 flap.
2. The rear baggage compartment aft of the rear door has no tie down net. However, the operator has thoughtfully supplied a brightly coloured carpet to throw over any cargo or bags. This rug has eyelets and tape attached to the retaining hooks in the floor. In other words there is no effective restraint.
3. The nose baggage compartment is not equipped with tie down devices or floor restraints. In this compartment are three metal wheel chocks, several empty soft drink bottles, a small metal ladder and various debris. The metal ladder is firmly wedged against thin electrical wiring emanating from behind the instrument panel and disappearing into the nose cone via the sidewall of the front baggage compartment. Everything in the baggage compartment is unrestrained and would float freely in turbulence.
4. Numerous oil leaks are visible through the front of the left engine cowl area with oil running from under the engine nacelle and through to the top surface of the flap area inboard of the engine. The operator is aware of the oil leak but says it is due to over-filling of the oil tank. He directs that that the contents should be 9 quarts maximum to minimize perceived oil loss. Both wheel wells also show signs of excess engine oil leaks.
5. Strong smell of fuel in the fuselage area when the aircraft is stationary. In the immediate vicinity of both cross-feed drains there is wet fuel stains on the fuselage belly with flow patterns extending several inches. The operator was previously advised but no action was taken. The problem of fuel leaks in this area are long-standing. Two wing fuel tank water drains drip fuel at one drop per 30 seconds on to the tarmac.
6. Autopilot when engaged causes very sudden in-flight manoeuvres and has to be hurriedly disengaged. There is no placard indicating an unserviceable autopilot and nothing in the m/r. The Century 111 autopilot control panel has a missing knob for roll mode – it is just a bare metal rod on which the knob is supposed to be attached. The calibration wheel on the autopilot box has unreadable graduations thus it is not possible to note a specific setting in daytime – worse at night, of course. There is a knob called “Auto Pilot Nav Selector” which can be selected to Nav1, Nav 2 or Off. There is no documentation on the specific use of this section of the autopilot. The operator’s policy is not to make the system serviceable because he deems it too expensive to rectify.
The aircraft flies single pilot IFR with no autopilot. This is apparently legal on passenger charter operations but not on RPT flights. Passengers should be entitled to the same degree of safety regardless of the category of flight. The operator crews RPT flights with two pilots, with the second pilot paying for the right seat under the guise of in command under supervision – but logging the total flight as “in command”. The autopilot has been unserviceable for 9 months and no action taken to rectify the problem. Single pilot IFR/IMC with no auto pilot is not conducive to a safe operation, regardless of the legalities.
7. Normally a green light appears when there is electrical power to the turn-coordinator. The light is inoperative. Next to the u/s light is an empty un-labelled lamp socket.
8. The two position voltage regulator switch is labeled only Main. There is apparently a second position hopefully for the Aux regulator if indeed one is installed. There is no Aux label on the switch assembly.
9. The circuit breaker panel has many obliterated decals or words with one or more letters missing. At night it is difficult to read the decals due grime and dirt or simply non-existent labels. The autopilot circuit breaker was out and easily reset because there is a piece of plastic or broken collar surrounding the circuit breaker shank. Nothing about this in the m/r. If the circuit breaker is inoperative or permanently collared out, then as a protection against circuit breaker resetting it is useless and potentially dangerous fire risk.
10. The green glide slope engaged light is inoperative on press-to-test.
11. There is a decal on the circuit breaker panel which on close scrutiny (impossible at night) says “Turn and Bank Left/Right”. There is however only one turn coordinator – not a Turn and Bank Indicator which is situated on the left instrument panel in front of the left seat pilot. There is no similar instrument in front of the RH seat pilot – only a couple of plugged holes where instruments were once installed.
The circuit breaker marked “Left Turn and Bank”, appears to be a false circuit breaker as it does not pull out and on closer inspection it is merely a black painted knob which looks exactly like a circuit breaker in shape and size. The circuit breaker labeled “RH Turn and Bank” is a real circuit breaker but there is no RH instrument for it to supply power to. One can imagine the confusion in event of electrical smoke or fire when the pseudo circuit breaker is found to be jammed.
11. There is a Stormscope installed. It is well advertised by a decal situated on the fuselage near the entrance door which says “Stormscope equipped.” An identical decal advertising the presence of the Stormscope is situated on the left fuselage sidewall adjacent to the circuit breaker panel. Maybe this is to give an added sense of security to the pilot. However, above the actual instrument is a decal marked Radar. There is also a circuit breaker marked Radar. Only problem is that the aircraft is not equipped with weather radar.
12. There is a set of normal looking rudder pedals for the copilot position. They are identical in size and shape to the pilot’s rudder pedals. However, there are no brakes on the copilot’s pedals. There is no decal warning of this, nothing in the Flight Manual or the Operations Manual and no mention in the maintenance release. Simply, one would not know if the brakes were either not working from the RH side, or if they were not installed. I know of one endorsement carried out on this particular aircraft where the instructor was not aware that brakes were not installed on the right hand seat pedals, until after the flight with a student undergoing conversion training. The pilot under training had commented on the heavy nosewheel steering problems, so the instructor took control to “free up” the nosewheel steering by applying alternate foot pressure to each pedal on his side. The brake “pressure” appeared to lock solid on his pedals and the aircraft started to veer off the tarmac towards a nearby obstruction. The instructor quickly told the student to take over control. Later it was discovered that the copilot’s pedals indeed had no braking capability. The aircraft had flown for hundreds of hours and previous pilots had been unaware of the lack of RH seat brakes.
13. There are two engine gauges. Each gauge has an integral oil pressure, oil temperature and CHT sub gauge. In this aircraft the colour coding of the various instruments within the main gauge display do not agree with each other. For example, one oil pressure gauge shows 10 PSI red line limit for the left engine while the right oil pressure gauge shows 25 PSI red line limit. The green normal oil pressure operating range is quite different between the two oil pressure gauges. The CHT left engine gauge indicates 200F as the lower limit on the needle while the right engine CHT lower limit shows 100F.
The varying size of temperature in degrees F scales on the two CHT gauges means that the needle positions are not generally parallel, thus requiring careful scrutiny of the actual readings – rather than a normal scan which looks for similar parallel readings within average temperature parameters. The left oil temperature gauge has no numbers – just a green arc and one red temperature limit mark. The right oil temperature gauge has graduations from 50F to 250F plus – with three colour codes of green, yellow, and red. This means that a normal scan of engine temperatures and pressures in flight is not possible in terms of normal or abnormal needle positions. Instead a close scrutiny of each needle is needed which becomes a problem at night where cockpit directional lighting is poor by even automobile standards.
14. It is impossible to read the Directional Gyro at night because the internal lighting is inoperative. One needs to shine a torch on the instrument or have cat’s eye vision to read compass headings.
15. The upper switch panel over the pilot’s head houses the magneto switches. On the panel is a sign which says “Alternators Press-to-Test”. This refers to alternator test buttons that were presumably once installed. Instead there are two empty holes drilled into the vinyl roof and no buttons to press.
16. Both mixture controls are misaligned. The rear limit (idle cut-off position) actually coincides with a decal marked “Lean” that itself is supposed to indicate typical cruise position of the mixture control when leaned correctly. In other words, if the pilot leaned the mixture levers to the position marked “Lean” both engines would stop. Similarly the full forward rich mixture limit stops one and a half inches from the forward stop. The available movement of the two mixture controls is only slightly more than half of the total quadrant distance between ICO and full rich lever position.
17. There is intolerable noise in the No 1 VHF set and it sounds like a parrot squawking. The No 2 ADF volume control (Bendix) has no decal indicating volume direction. The HF volume control knob is un-marked and the decal obliterated. Similarly the circuit breaker panel has various switches such as landing and taxi light controls. There is no decal showing on/off positions which is confusing, particularly as the alternator field switches lay fore and aft.
18. The metal vertical cover which protects the left engine fire fuel shut-off handles (behind the pilot’s seat) from inadvertent actuation, does a good job indeed. It is tightly jammed and no amount of effort could move it in event of an engine fire - apart from using a set of pliars or a screw driver. The right engine fire fuel handle cover plate is not jammed. It is so loose that it is normally left laying on the cockpit floor.
19. On top of the right engine cowl a crack is evident adjacent to the hinge line of the oil cap cover. The crack is proceeding nicely but there is no stop drilling present.
20. Exposed and unprotected electrical wiring is readily visible coming from behind the left fuselage vinyl wall covering, and running behind the copilot’s seat and leading to the fuel system panel. The wiring is partially secured by masking tape which has peeled away. As the gap between the copilot’s seat and the passenger compartment wooden separation panel is used for maps, brief cases etc, it is easy to snag the wiring.
21. There is an electrically operated passenger seat belt sign attached to a portable wooden bulkhead. The box in which the sign is installed has a thick dark brown plastic cover. The seat belt signs are not visible in daylight, but with much peering one can just see the sign at night. It is quite useless for it’s task in daylight and only maginally better at night. There is no sign to indicate to passengers that the box displayed to their view is indeed a seat belts fastened device. It is just looks like a dark coloured box with no function.
22. Now here is a real beauty. Above the front right passenger window there is some light coloured masking tape. A closer inspection reveals the faded word EXIT in red but under the masking tape. It would be impossible to read at night in a dim passenger cabin. It is difficult to see in bright daylight. The emergency exit handle is covered by very tough plastic that requires a heavy pull to break in order to get at the handle. Lacerated fingers would occur.
The handle assembly is situated in a position between two windows. There is no positive indication which of the two passenger windows is the emergency exit – especially as the small red EXIT sign is covered over with masking tape. There is a decal which displays the following instruction: Emergency Exit – Lift Latch – Pull pin-Push window out. Which window? So there are two contradictory directions; One says Pull Pin, Lift Latch and the other says Pull handle Down. Very confusing even for the pilot, let alone a passenger at night. There is no doubt that the emergency exit window should be clearly outlined and the decal confusion sorted out.
23. The rear door can be used as an emergency exit. There is no decal indication that it can be used for this purpose. A passenger briefing card is available but the Navajo door opening procedure for the rear exit is complicated. In this aircraft the vital “Press-to-Release” knob which allows the main hatch to be operated that unlocks the exit door, is painted in faded white with what appears to be a faded red touch to it. There is no indication of the importance of that button to release the latch mechanism.
There is also a chain and bolt attached to the door area which is supposed to be attached after the door is locked closed, in order to prevent inadvertent door opening in flight. With the chain in place the door can only open an inch or so. There is no mention on the passenger briefing cards of the function of this bolt and chain and no decals or instructions adjacent to the door of the vital need to undo the chain and bolt before attempting to operate the exit mechanism. In other words the whole emergency exit policy in this Navajo is shambles. But all is not yet lost because to balance things up there is a very clearly displayed sign opposite the rear exit which says “Thank you for not smoking”.
24. In front of the copilot position are situated the cockpit heat controls. Next to the levers is a decal marked “Fuel On”. But there is no switch to associate with the decal –just another empty hole where presumably there was once a switch.
25. The fuel tank caps have a red decal stating that 100 octane fuel should be used. However the decal stating fuel tank capacity is missing on all caps.
26. The passenger emergency exit windows are not marked on the outside of the fuselage for ingress into the cabin. There is also no instruction on the outside of the rear door on how to open the door from the outside in event of an emergency.
27. In cruise the No 2 fuel pressure needle shows 3 PSI in excess of the red line limit.
28. The taxi light gives only five metres forward illumination – about the same as the parking lights on a car. In other words useless for obstacle illumination.
29. The right windscreen has numerous small nicks, cracks and crazed areas. Landing at night, runway lights show very diffused patterns through the windscreen and would be impossible to have adequate vision towards the sun.
30. The left oil pressure gauge shows a green band 30 to 60 PSI. The right oil pressure gauge shows a yellow caution band 30-60 PSI – then a green sector. Very confusing.
31. DME inoperative on last leg. Common defect on this aircraft.
32. Both pilot’s sun-visors flop down during take off, and in flight they dangle loosely and apparently have been like this for months.
33. There is a “company” checklist situated in the front of the Flight Manual. There is no specific pre-take off vital actions on this checklist. There is no check that the autopilot should be off for take off, no checklist of mixtures rich, no check of fuel pumps on, no fuel contents check for take off, no pitch full fine, no flight control check, no descent and approach checklist. I suppose there is no legal requirement for an approved checklist in the cockpit, but surely any operator would ensure certain airmanship items would be included in the company checklist in the aircraft.
………………………………………………………………………………………….
Comments: Most GA pilots have learned to live with the type of unserviceablities I have described above. Some of these defects are minor, but in an emergency their nuisance value can add up to being more serious and certainly distracting to the pilot. This particular owner/operator could at little expense rectify 90% of the defects. Unfortunately the pilot who recorded these defects in the maintenance release (no one did) would soon find himself out of a job – hence the clean maintenance release, regardless of unrecorded defects, on this and many GA aircraft.
It is annoying that CASA operations and airworthiness inspectors apparently do not investigate these dodgy operators unless led by the nose – and then follow up action rarely takes place. Surely an airworthiness inspector could ramp check several aircraft each week just by opening the door and looking for the obvious, like I did. I was just an observer on the flight – not the pilot-in-command.
The word would soon get around that frequent diligent on the spot inspections were causing embarrassment to operators and presumably things would improve on the maintenance front. The state of this particular Navajo based at Essendon, I believe represents just the tip of the iceberg among countless GA operators, particularly those away from CASA surveillance. I know of one country airport operator who when advised by CASA that a scheduled inspection party will arrive on a nominated date, flies his worst aircraft away to another aerodrome, returning when the inspection team has left.
The following additional report on a Cessna 310 also based at Essendon, may convince readers that these are not isolated events.
............................................................ ....................................
CAIR Report – Aztec:
The purpose of the flight was to endorse a pilot on type. I arrived at the airport to find that the pilot under instruction had been verbally briefed by the company chief pilot that there were problems with the cockpit door which was hard to close and which had previously opened in flight. He said that if the door came open on final, the pilot should increase the approach speed by five knots. This statement indicated that the door defect was a known event on this particular aircraft. The chief pilot further advised of a faulty autopilot pitch control channel and1. The stall warning system failed to operate during stall recovery demonstrations.
2. The landing gear warning horn failed to operate and the red gear warning light in the gear lever failed to illuminate with gear up and throttles retarded.
3. Control column movement fore and aft caused squealing noises due lack of lubrication. This could be clearly heard during the landing hold off and when checking freedom of movement.
4. The Turn Coordinator was abnormally noisy during gyro run up.
5. Both CHT gauges appeared either unserviceable or unusually under-reading. Neither needle left the bottom (cold) stop although the right CHT needle did flicker higher a couple of times. As I had not flown this particular aircraft before and the OAT was only 10C, I accepted these low readings during run-up, but once airborne there was no discernable increase above the low stop.
6. Both EGT gauges inoperative.
7. .
8. The left engine manifold pressure needle (dual needles in a single gauge) frequently failed to respond to power changes until a differential of at least 6 inches of manifold pressure occurred. The needle would then move sluggishly to take up an appropriate reading. This fault showed through out the flight whenever the throttles were repositioned.
9. The radio switch panel displayed a switch marked No 2 VHF.Nav receiver and another marked as No 2 VHF transmitter. In fact there was only one VHF and one VHF-Nav. These switches should be labelled as inoperative.
10. The feedback on VHF transmissions was scratchy and practically unreadable.
11. On two ILS approaches, while at 3 miles from the runway, the localiser needle showed one dot off centre with the aircraft visually aligned on the runway centre line. On one approach there was a rapid oscillation of the localiser needle on 3 miles final. Oscillation was less on the second ILS approach.
12. The autopilot over-controlled in roll and a severe pitch/bunt occurred when the pitch channel was engaged. No further attempts were made to experiment with the auto-pilot.
13. Attached to the pilot’s control wheel were two unidentified switches. One had the word ‘Winchester Electronics Incorporated” etched on the assembly. This was a press-to-transmit type switch and had it’s button missing, leaving a very nasty sharp threaded point for the pilot to push. The other switch was concealed under the wheel and not readily noticeable until inadvertently felt. It was a black toggle switch, spring loaded to centre, and operable in either direction. There was no labeling to indicate the purpose of either switch and no Flight Manual annotation.
14. With both mixture controls full forward, their position was at least two inches from the top edge of the quadrant, and looked as though they were actually in a mid-lean position. This may be an Aztec characteristic?
15. During run-up, the right pitch control was abnormally stiff to operate throughout the full range from Fine to Feather.
16. The parking brake was useless. As soon as moderate power was applied to any engine for run-up, the aircraft would move forward and veer left.
17. The right brake was weak during landing. Equal foot pressure on both pedals produced a marked turn to the left.
18. The altimeter on the copilot’s side showed 120 ft less than the pilot’s altimeter for same QNH. This was on the ground. There was an 80 ft difference when aairborne. The right altimeter was outside IFR limits.
19. On two ILS approaches, the marker beacon lights and audio for the OM and MM failed to operate. The light globes also failed to operate on press to test.
20. The emergency exit window (passenger) is not labeled in any form. There is a single red handle beneath the window. This handle faces forward, but is unmarked. It would be easy for a passenger to inadvertently knock the handle with an elbow.
21. At 1100 rpm, the right engine manifold gauge needle oscillates rapidly over a 150 rpm range.
22. The pilot’s overhead vent control has an exposed metal shaft. The plastic round button is missing.
23. The internal dim/bright lights on the ADF digital control panel appear to be stuck in the dim position.
24. There is a radio rheostat switch labeled “Radio Light”. The switch may be disconnected or inoperative, as it does not appear to illuminate anything. If so, it should be labeled Inoperative.
25. The flap indicator needle indicates slight flap extended, although the flaps are confirmed visually up.
26. Most circuit breakers are underneath the left instrument panel out of sight of the pilot in the normal seated position. A portion of the decal serving these circuit breakers has been obliterated due wear and it takes time to read exactly what services are covered. Impossible at night.
27. A fire extinguisher is installed under the copilot’s seat. A label reveals that the last inspection was in 1986.
28. There is no POH in the aircraft. The Flight Manual did not have a copy of the C of R inside.
29. The ASI has no markings for Vmca, or blue line speed.
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Comments. In view of the inoperative stall warning and gear unsafe warning, I endorsed the maintenance release as aircraft un-airworthy. This Aztec is used for charter flying by the operator. Signatures on the maintenance release indicate that at least 8 pilots have flown this aircraft since the maintenance release was issued. It is difficult to believe that there were no defects apparently discovered during the 60 hours of flying until I flew it. The chief pilot was clearly aware of some of the defects because he cautioned the pilot under conversion prior to our flight.
Many of the defects must have been current during the last 100 hourly inspection, but the maintenance organization have appeared to missed them – or more likely deliberately ignored their presence. I understand that the operator has recently undergone routine surveillance by CASA inspectors. Presumably this would have included an inspection of airworthiness aspects of this aircraft. If so, the inspectors concerned perhaps lacked their usual vigour?
A short flight test would have revealed the in-flight defects such as those listed in this report. After all, cars are subject to a short road test to renew some roadworthy issues, so perhaps old aircraft should be required to undergo the same appropriate airworthiness flight tests as part of charter approval for the type.
If nothing else, there should be an airworthiness investigation on the positioning of the second AH which is required for IFR charter. I have seen this problem on many GA types, although this particular Aztec was the worst example. There is little point in having flight instrument redundancy if the pilot faces serious aircraft handling problems when forced to fall back on the spare AH which may be outside his normal scan. The Monarch Airlines accident inquiry revealed a similar problem in instrumentation.
Airworthiness authorities are rightly concerned with correctness of paper work during routine operator surveillance. From my experience there is a clear need for inspectors to crawl around a few cockpits. Many of the defects that I have listed on this Aztec should have been readily apparent to a diligent flying operations or airworthiness inspector who took time to open the door – that being the very first defect.
…………………………………………
LOOKING UNDER THE CARPET.
From an old CAIR report:
I recently sat in the right hand seat of a Navajo engaged on a charter flight EN-Swan Hill-EN. The aircraft was based at Essendon. With several spare hours on the ground, and working on the adage “The Devil finds work for idle hands” I listed all the things wrong with that aircraft that could cause Human Factors problems particularly to an inexperienced IFR pilot, or a pilot not current on this particular aircraft. The maintenance release was squeaky clean of all endorsements and the aircraft had a shiny new paint job on the outside, but a diligent airworthiness inspector would surely have picked up the following on a ramp check – or maybe however, he would think it all too minor to worry about?
It took me only 15 minutes to find the following defects seen from a pilot’s point of view but almost one hour to write them down. Starting with:
1. A placard on the pilot’s side-consul states that the aircraft is limited to a maximum landing flap setting of 25 degrees. The Flight Manual has a similar notice with a requirement that 2 knots be added to the flight manual Vref speed for 40 flap when landing with 25 flap. The flap indicator shows a white sector band from up to 15 flap –and nothing else on the gauge to indicate exactly what flap setting in degrees is available beyond 15. When selecting the flap to down, the needle goes beyond 15 by ¾ inch into the unmarked areas and there is no indication if the flap micro-switch stops the flaps (via a limit switch) at 25 or 40. There is no external mark on the wings to indicate current flap position. This is common to many Navajos I have seen. In short, the flap indicator is misleading and impossible to comply with the flight manual restriction because there are no markings beyond 15 flap.
2. The rear baggage compartment aft of the rear door has no tie down net. However, the operator has thoughtfully supplied a brightly coloured carpet to throw over any cargo or bags. This rug has eyelets and tape attached to the retaining hooks in the floor. In other words there is no effective restraint.
3. The nose baggage compartment is not equipped with tie down devices or floor restraints. In this compartment are three metal wheel chocks, several empty soft drink bottles, a small metal ladder and various debris. The metal ladder is firmly wedged against thin electrical wiring emanating from behind the instrument panel and disappearing into the nose cone via the sidewall of the front baggage compartment. Everything in the baggage compartment is unrestrained and would float freely in turbulence.
4. Numerous oil leaks are visible through the front of the left engine cowl area with oil running from under the engine nacelle and through to the top surface of the flap area inboard of the engine. The operator is aware of the oil leak but says it is due to over-filling of the oil tank. He directs that that the contents should be 9 quarts maximum to minimize perceived oil loss. Both wheel wells also show signs of excess engine oil leaks.
5. Strong smell of fuel in the fuselage area when the aircraft is stationary. In the immediate vicinity of both cross-feed drains there is wet fuel stains on the fuselage belly with flow patterns extending several inches. The operator was previously advised but no action was taken. The problem of fuel leaks in this area are long-standing. Two wing fuel tank water drains drip fuel at one drop per 30 seconds on to the tarmac.
6. Autopilot when engaged causes very sudden in-flight manoeuvres and has to be hurriedly disengaged. There is no placard indicating an unserviceable autopilot and nothing in the m/r. The Century 111 autopilot control panel has a missing knob for roll mode – it is just a bare metal rod on which the knob is supposed to be attached. The calibration wheel on the autopilot box has unreadable graduations thus it is not possible to note a specific setting in daytime – worse at night, of course. There is a knob called “Auto Pilot Nav Selector” which can be selected to Nav1, Nav 2 or Off. There is no documentation on the specific use of this section of the autopilot. The operator’s policy is not to make the system serviceable because he deems it too expensive to rectify.
The aircraft flies single pilot IFR with no autopilot. This is apparently legal on passenger charter operations but not on RPT flights. Passengers should be entitled to the same degree of safety regardless of the category of flight. The operator crews RPT flights with two pilots, with the second pilot paying for the right seat under the guise of in command under supervision – but logging the total flight as “in command”. The autopilot has been unserviceable for 9 months and no action taken to rectify the problem. Single pilot IFR/IMC with no auto pilot is not conducive to a safe operation, regardless of the legalities.
7. Normally a green light appears when there is electrical power to the turn-coordinator. The light is inoperative. Next to the u/s light is an empty un-labelled lamp socket.
8. The two position voltage regulator switch is labeled only Main. There is apparently a second position hopefully for the Aux regulator if indeed one is installed. There is no Aux label on the switch assembly.
9. The circuit breaker panel has many obliterated decals or words with one or more letters missing. At night it is difficult to read the decals due grime and dirt or simply non-existent labels. The autopilot circuit breaker was out and easily reset because there is a piece of plastic or broken collar surrounding the circuit breaker shank. Nothing about this in the m/r. If the circuit breaker is inoperative or permanently collared out, then as a protection against circuit breaker resetting it is useless and potentially dangerous fire risk.
10. The green glide slope engaged light is inoperative on press-to-test.
11. There is a decal on the circuit breaker panel which on close scrutiny (impossible at night) says “Turn and Bank Left/Right”. There is however only one turn coordinator – not a Turn and Bank Indicator which is situated on the left instrument panel in front of the left seat pilot. There is no similar instrument in front of the RH seat pilot – only a couple of plugged holes where instruments were once installed.
The circuit breaker marked “Left Turn and Bank”, appears to be a false circuit breaker as it does not pull out and on closer inspection it is merely a black painted knob which looks exactly like a circuit breaker in shape and size. The circuit breaker labeled “RH Turn and Bank” is a real circuit breaker but there is no RH instrument for it to supply power to. One can imagine the confusion in event of electrical smoke or fire when the pseudo circuit breaker is found to be jammed.
11. There is a Stormscope installed. It is well advertised by a decal situated on the fuselage near the entrance door which says “Stormscope equipped.” An identical decal advertising the presence of the Stormscope is situated on the left fuselage sidewall adjacent to the circuit breaker panel. Maybe this is to give an added sense of security to the pilot. However, above the actual instrument is a decal marked Radar. There is also a circuit breaker marked Radar. Only problem is that the aircraft is not equipped with weather radar.
12. There is a set of normal looking rudder pedals for the copilot position. They are identical in size and shape to the pilot’s rudder pedals. However, there are no brakes on the copilot’s pedals. There is no decal warning of this, nothing in the Flight Manual or the Operations Manual and no mention in the maintenance release. Simply, one would not know if the brakes were either not working from the RH side, or if they were not installed. I know of one endorsement carried out on this particular aircraft where the instructor was not aware that brakes were not installed on the right hand seat pedals, until after the flight with a student undergoing conversion training. The pilot under training had commented on the heavy nosewheel steering problems, so the instructor took control to “free up” the nosewheel steering by applying alternate foot pressure to each pedal on his side. The brake “pressure” appeared to lock solid on his pedals and the aircraft started to veer off the tarmac towards a nearby obstruction. The instructor quickly told the student to take over control. Later it was discovered that the copilot’s pedals indeed had no braking capability. The aircraft had flown for hundreds of hours and previous pilots had been unaware of the lack of RH seat brakes.
13. There are two engine gauges. Each gauge has an integral oil pressure, oil temperature and CHT sub gauge. In this aircraft the colour coding of the various instruments within the main gauge display do not agree with each other. For example, one oil pressure gauge shows 10 PSI red line limit for the left engine while the right oil pressure gauge shows 25 PSI red line limit. The green normal oil pressure operating range is quite different between the two oil pressure gauges. The CHT left engine gauge indicates 200F as the lower limit on the needle while the right engine CHT lower limit shows 100F.
The varying size of temperature in degrees F scales on the two CHT gauges means that the needle positions are not generally parallel, thus requiring careful scrutiny of the actual readings – rather than a normal scan which looks for similar parallel readings within average temperature parameters. The left oil temperature gauge has no numbers – just a green arc and one red temperature limit mark. The right oil temperature gauge has graduations from 50F to 250F plus – with three colour codes of green, yellow, and red. This means that a normal scan of engine temperatures and pressures in flight is not possible in terms of normal or abnormal needle positions. Instead a close scrutiny of each needle is needed which becomes a problem at night where cockpit directional lighting is poor by even automobile standards.
14. It is impossible to read the Directional Gyro at night because the internal lighting is inoperative. One needs to shine a torch on the instrument or have cat’s eye vision to read compass headings.
15. The upper switch panel over the pilot’s head houses the magneto switches. On the panel is a sign which says “Alternators Press-to-Test”. This refers to alternator test buttons that were presumably once installed. Instead there are two empty holes drilled into the vinyl roof and no buttons to press.
16. Both mixture controls are misaligned. The rear limit (idle cut-off position) actually coincides with a decal marked “Lean” that itself is supposed to indicate typical cruise position of the mixture control when leaned correctly. In other words, if the pilot leaned the mixture levers to the position marked “Lean” both engines would stop. Similarly the full forward rich mixture limit stops one and a half inches from the forward stop. The available movement of the two mixture controls is only slightly more than half of the total quadrant distance between ICO and full rich lever position.
17. There is intolerable noise in the No 1 VHF set and it sounds like a parrot squawking. The No 2 ADF volume control (Bendix) has no decal indicating volume direction. The HF volume control knob is un-marked and the decal obliterated. Similarly the circuit breaker panel has various switches such as landing and taxi light controls. There is no decal showing on/off positions which is confusing, particularly as the alternator field switches lay fore and aft.
18. The metal vertical cover which protects the left engine fire fuel shut-off handles (behind the pilot’s seat) from inadvertent actuation, does a good job indeed. It is tightly jammed and no amount of effort could move it in event of an engine fire - apart from using a set of pliars or a screw driver. The right engine fire fuel handle cover plate is not jammed. It is so loose that it is normally left laying on the cockpit floor.
19. On top of the right engine cowl a crack is evident adjacent to the hinge line of the oil cap cover. The crack is proceeding nicely but there is no stop drilling present.
20. Exposed and unprotected electrical wiring is readily visible coming from behind the left fuselage vinyl wall covering, and running behind the copilot’s seat and leading to the fuel system panel. The wiring is partially secured by masking tape which has peeled away. As the gap between the copilot’s seat and the passenger compartment wooden separation panel is used for maps, brief cases etc, it is easy to snag the wiring.
21. There is an electrically operated passenger seat belt sign attached to a portable wooden bulkhead. The box in which the sign is installed has a thick dark brown plastic cover. The seat belt signs are not visible in daylight, but with much peering one can just see the sign at night. It is quite useless for it’s task in daylight and only maginally better at night. There is no sign to indicate to passengers that the box displayed to their view is indeed a seat belts fastened device. It is just looks like a dark coloured box with no function.
22. Now here is a real beauty. Above the front right passenger window there is some light coloured masking tape. A closer inspection reveals the faded word EXIT in red but under the masking tape. It would be impossible to read at night in a dim passenger cabin. It is difficult to see in bright daylight. The emergency exit handle is covered by very tough plastic that requires a heavy pull to break in order to get at the handle. Lacerated fingers would occur.
The handle assembly is situated in a position between two windows. There is no positive indication which of the two passenger windows is the emergency exit – especially as the small red EXIT sign is covered over with masking tape. There is a decal which displays the following instruction: Emergency Exit – Lift Latch – Pull pin-Push window out. Which window? So there are two contradictory directions; One says Pull Pin, Lift Latch and the other says Pull handle Down. Very confusing even for the pilot, let alone a passenger at night. There is no doubt that the emergency exit window should be clearly outlined and the decal confusion sorted out.
23. The rear door can be used as an emergency exit. There is no decal indication that it can be used for this purpose. A passenger briefing card is available but the Navajo door opening procedure for the rear exit is complicated. In this aircraft the vital “Press-to-Release” knob which allows the main hatch to be operated that unlocks the exit door, is painted in faded white with what appears to be a faded red touch to it. There is no indication of the importance of that button to release the latch mechanism.
There is also a chain and bolt attached to the door area which is supposed to be attached after the door is locked closed, in order to prevent inadvertent door opening in flight. With the chain in place the door can only open an inch or so. There is no mention on the passenger briefing cards of the function of this bolt and chain and no decals or instructions adjacent to the door of the vital need to undo the chain and bolt before attempting to operate the exit mechanism. In other words the whole emergency exit policy in this Navajo is shambles. But all is not yet lost because to balance things up there is a very clearly displayed sign opposite the rear exit which says “Thank you for not smoking”.
24. In front of the copilot position are situated the cockpit heat controls. Next to the levers is a decal marked “Fuel On”. But there is no switch to associate with the decal –just another empty hole where presumably there was once a switch.
25. The fuel tank caps have a red decal stating that 100 octane fuel should be used. However the decal stating fuel tank capacity is missing on all caps.
26. The passenger emergency exit windows are not marked on the outside of the fuselage for ingress into the cabin. There is also no instruction on the outside of the rear door on how to open the door from the outside in event of an emergency.
27. In cruise the No 2 fuel pressure needle shows 3 PSI in excess of the red line limit.
28. The taxi light gives only five metres forward illumination – about the same as the parking lights on a car. In other words useless for obstacle illumination.
29. The right windscreen has numerous small nicks, cracks and crazed areas. Landing at night, runway lights show very diffused patterns through the windscreen and would be impossible to have adequate vision towards the sun.
30. The left oil pressure gauge shows a green band 30 to 60 PSI. The right oil pressure gauge shows a yellow caution band 30-60 PSI – then a green sector. Very confusing.
31. DME inoperative on last leg. Common defect on this aircraft.
32. Both pilot’s sun-visors flop down during take off, and in flight they dangle loosely and apparently have been like this for months.
33. There is a “company” checklist situated in the front of the Flight Manual. There is no specific pre-take off vital actions on this checklist. There is no check that the autopilot should be off for take off, no checklist of mixtures rich, no check of fuel pumps on, no fuel contents check for take off, no pitch full fine, no flight control check, no descent and approach checklist. I suppose there is no legal requirement for an approved checklist in the cockpit, but surely any operator would ensure certain airmanship items would be included in the company checklist in the aircraft.
………………………………………………………………………………………….
Comments: Most GA pilots have learned to live with the type of unserviceablities I have described above. Some of these defects are minor, but in an emergency their nuisance value can add up to being more serious and certainly distracting to the pilot. This particular owner/operator could at little expense rectify 90% of the defects. Unfortunately the pilot who recorded these defects in the maintenance release (no one did) would soon find himself out of a job – hence the clean maintenance release, regardless of unrecorded defects, on this and many GA aircraft.
It is annoying that CASA operations and airworthiness inspectors apparently do not investigate these dodgy operators unless led by the nose – and then follow up action rarely takes place. Surely an airworthiness inspector could ramp check several aircraft each week just by opening the door and looking for the obvious, like I did. I was just an observer on the flight – not the pilot-in-command.
The word would soon get around that frequent diligent on the spot inspections were causing embarrassment to operators and presumably things would improve on the maintenance front. The state of this particular Navajo based at Essendon, I believe represents just the tip of the iceberg among countless GA operators, particularly those away from CASA surveillance. I know of one country airport operator who when advised by CASA that a scheduled inspection party will arrive on a nominated date, flies his worst aircraft away to another aerodrome, returning when the inspection team has left.
The following additional report on a Cessna 310 also based at Essendon, may convince readers that these are not isolated events.
............................................................ ....................................
CAIR Report – Aztec:
The purpose of the flight was to endorse a pilot on type. I arrived at the airport to find that the pilot under instruction had been verbally briefed by the company chief pilot that there were problems with the cockpit door which was hard to close and which had previously opened in flight. He said that if the door came open on final, the pilot should increase the approach speed by five knots. This statement indicated that the door defect was a known event on this particular aircraft. The chief pilot further advised of a faulty autopilot pitch control channel and1. The stall warning system failed to operate during stall recovery demonstrations.
2. The landing gear warning horn failed to operate and the red gear warning light in the gear lever failed to illuminate with gear up and throttles retarded.
3. Control column movement fore and aft caused squealing noises due lack of lubrication. This could be clearly heard during the landing hold off and when checking freedom of movement.
4. The Turn Coordinator was abnormally noisy during gyro run up.
5. Both CHT gauges appeared either unserviceable or unusually under-reading. Neither needle left the bottom (cold) stop although the right CHT needle did flicker higher a couple of times. As I had not flown this particular aircraft before and the OAT was only 10C, I accepted these low readings during run-up, but once airborne there was no discernable increase above the low stop.
6. Both EGT gauges inoperative.
7. .
8. The left engine manifold pressure needle (dual needles in a single gauge) frequently failed to respond to power changes until a differential of at least 6 inches of manifold pressure occurred. The needle would then move sluggishly to take up an appropriate reading. This fault showed through out the flight whenever the throttles were repositioned.
9. The radio switch panel displayed a switch marked No 2 VHF.Nav receiver and another marked as No 2 VHF transmitter. In fact there was only one VHF and one VHF-Nav. These switches should be labelled as inoperative.
10. The feedback on VHF transmissions was scratchy and practically unreadable.
11. On two ILS approaches, while at 3 miles from the runway, the localiser needle showed one dot off centre with the aircraft visually aligned on the runway centre line. On one approach there was a rapid oscillation of the localiser needle on 3 miles final. Oscillation was less on the second ILS approach.
12. The autopilot over-controlled in roll and a severe pitch/bunt occurred when the pitch channel was engaged. No further attempts were made to experiment with the auto-pilot.
13. Attached to the pilot’s control wheel were two unidentified switches. One had the word ‘Winchester Electronics Incorporated” etched on the assembly. This was a press-to-transmit type switch and had it’s button missing, leaving a very nasty sharp threaded point for the pilot to push. The other switch was concealed under the wheel and not readily noticeable until inadvertently felt. It was a black toggle switch, spring loaded to centre, and operable in either direction. There was no labeling to indicate the purpose of either switch and no Flight Manual annotation.
14. With both mixture controls full forward, their position was at least two inches from the top edge of the quadrant, and looked as though they were actually in a mid-lean position. This may be an Aztec characteristic?
15. During run-up, the right pitch control was abnormally stiff to operate throughout the full range from Fine to Feather.
16. The parking brake was useless. As soon as moderate power was applied to any engine for run-up, the aircraft would move forward and veer left.
17. The right brake was weak during landing. Equal foot pressure on both pedals produced a marked turn to the left.
18. The altimeter on the copilot’s side showed 120 ft less than the pilot’s altimeter for same QNH. This was on the ground. There was an 80 ft difference when aairborne. The right altimeter was outside IFR limits.
19. On two ILS approaches, the marker beacon lights and audio for the OM and MM failed to operate. The light globes also failed to operate on press to test.
20. The emergency exit window (passenger) is not labeled in any form. There is a single red handle beneath the window. This handle faces forward, but is unmarked. It would be easy for a passenger to inadvertently knock the handle with an elbow.
21. At 1100 rpm, the right engine manifold gauge needle oscillates rapidly over a 150 rpm range.
22. The pilot’s overhead vent control has an exposed metal shaft. The plastic round button is missing.
23. The internal dim/bright lights on the ADF digital control panel appear to be stuck in the dim position.
24. There is a radio rheostat switch labeled “Radio Light”. The switch may be disconnected or inoperative, as it does not appear to illuminate anything. If so, it should be labeled Inoperative.
25. The flap indicator needle indicates slight flap extended, although the flaps are confirmed visually up.
26. Most circuit breakers are underneath the left instrument panel out of sight of the pilot in the normal seated position. A portion of the decal serving these circuit breakers has been obliterated due wear and it takes time to read exactly what services are covered. Impossible at night.
27. A fire extinguisher is installed under the copilot’s seat. A label reveals that the last inspection was in 1986.
28. There is no POH in the aircraft. The Flight Manual did not have a copy of the C of R inside.
29. The ASI has no markings for Vmca, or blue line speed.
……………………………………………………………………………………………
Comments. In view of the inoperative stall warning and gear unsafe warning, I endorsed the maintenance release as aircraft un-airworthy. This Aztec is used for charter flying by the operator. Signatures on the maintenance release indicate that at least 8 pilots have flown this aircraft since the maintenance release was issued. It is difficult to believe that there were no defects apparently discovered during the 60 hours of flying until I flew it. The chief pilot was clearly aware of some of the defects because he cautioned the pilot under conversion prior to our flight.
Many of the defects must have been current during the last 100 hourly inspection, but the maintenance organization have appeared to missed them – or more likely deliberately ignored their presence. I understand that the operator has recently undergone routine surveillance by CASA inspectors. Presumably this would have included an inspection of airworthiness aspects of this aircraft. If so, the inspectors concerned perhaps lacked their usual vigour?
A short flight test would have revealed the in-flight defects such as those listed in this report. After all, cars are subject to a short road test to renew some roadworthy issues, so perhaps old aircraft should be required to undergo the same appropriate airworthiness flight tests as part of charter approval for the type.
If nothing else, there should be an airworthiness investigation on the positioning of the second AH which is required for IFR charter. I have seen this problem on many GA types, although this particular Aztec was the worst example. There is little point in having flight instrument redundancy if the pilot faces serious aircraft handling problems when forced to fall back on the spare AH which may be outside his normal scan. The Monarch Airlines accident inquiry revealed a similar problem in instrumentation.
Airworthiness authorities are rightly concerned with correctness of paper work during routine operator surveillance. From my experience there is a clear need for inspectors to crawl around a few cockpits. Many of the defects that I have listed on this Aztec should have been readily apparent to a diligent flying operations or airworthiness inspector who took time to open the door – that being the very first defect.
…………………………………………
I know of an AWI that pinged a poor 300 hour pilot for having a ripped roof lining. It was not hanging down or obstructing the cabin, just a small rip probably cause by a fishing rod or something similar. The AWI made it very clear that it was a defect and needed to be endorsed on the MR.
Lets also not forget that if there is any open entry on the MR the aircraft can not fly, it is grounded. Why do people insist that a pilot can ignore a defect written on the MR?
Read CAR 47(1) and (1A).
So if you can enter a " NAD " qualified item on the MR without effecting the flight legalities why not use the Snag Book
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Read CAR 47(1) and (1A).
It is pretty easy, if there is a defect that is not a show stopper you write NAD beside it.
BTW I am not being smart, I am always open to learn new tricks and pick up on items I might have missed or misunderstood. Although Pprune can be a bit rough sometimes, more often than not posters bring up valuable views/information and point many in the right direction.
I personally don't think that the current regs and their interpretation helps the situation. You've got different CASA offices with different opinions, combined with a wide variety of opinions in the industry, all with a set of regs that are anything but complete and readable by your average person (pilot or engineer).
MR requirements from the CAR's
From CAR133
Subject to regulation 317 and regulation 21.197 of CASR, the pilot in command of an Australian aircraft must not commence a flight if each of the following requirements is not satisfied: (a) the aircraft has a nationality mark and a registration mark painted on, or affixed to, it in accordance with Part 45 of CASR;
(c) the flight is not in contravention of any condition that:
(i) is set out or referred to in the maintenance release or in any other document approved for use as an alternative to the maintenance release for the purposes of regulation 49, or subregulation 43 (10); or
(ii) is applicable to the maintenance release by virtue of a direction given under regulation 44;
(d) any maintenance that is required to be carried out before the commencement of the flight, or that will be required to be carried out before the expiration of the flight, to comply with any requirement or condition imposed under these regulations with respect to the aircraft has been certified, in accordance with regulation 42ZE or 42ZN, to have been completed;
AND (from CAR49)
Permissible unserviceabilities to be endorsed on maintenance releases
(1) This regulation applies to each of the following persons in relation to an aircraft in respect of which a maintenance release is in force:
(a) the holder of the certificate of registration for the aircraft;
(b) the operator of the aircraft;
(c) a flight crew member of the aircraft;
(d) a person who is permitted by regulation 42ZC or 42ZD to carry out maintenance on the aircraft.
(2) If:
(a) an aircraft in respect of which a maintenance release is in force has developed a defect, or has suffered damage, that is a permissible unserviceability; and
(b) there is a likelihood that the aircraft will be flown before the permissible unserviceability is rectified;
a person mentioned in subregulation (1), who becomes aware of the defect or damage, must endorse the maintenance release, or other document approved for use as an alternative to the maintenance release for the purposes of this regulation, in the manner set out in subregulation (3).
Penalty: 25 penalty units.
(3) For subregulation (2), the maintenance release or other document must be signed by the person mentioned in subregulation (1), and must:
(a) set out each permissible unserviceability that exists with respect to the aircraft; and
(b) set out the conditions (if any) with respect to the use of the aircraft with those permissible unserviceabilities set out in any direction given under regulation 37 in relation to those permissible unserviceabilities as are not set out in any operations manual issued with respect to the aircraft or in Part 20 of the Civil Aviation Orders; and
(c) state that the maintenance release has effect subject to those conditions, whether set out in the maintenance release or the other document or otherwise.
Thus, if you endorse a maintenance release with a minor (MEL acceptable or otherwise minor) defect and indicate that there are no conditions imposed by this defect the aircraft may be flown.
CAR 50 covers major defects which should ground the aircraft, however the law surrounding the MR is that you must provide an endorsement to notify the registered operator and any pilots likely to fly the aircraft. The PIC then makes a decision as to whether the to fly with the defect, get LAME advice or not fly. Different pilots may make different decisions (EG: blown landing light may be a no go for a pilot doing night flights but acceptable to one intending a daylight only flight).
Either way unless the MR is actually endorsed with "not to be flown" (a condition) or similar it is NOT grounded. The only exception to this (under CAR 133D above) is if maintenance is required under legislation (Eg: AD's)
Subject to regulation 317 and regulation 21.197 of CASR, the pilot in command of an Australian aircraft must not commence a flight if each of the following requirements is not satisfied: (a) the aircraft has a nationality mark and a registration mark painted on, or affixed to, it in accordance with Part 45 of CASR;
(c) the flight is not in contravention of any condition that:
(i) is set out or referred to in the maintenance release or in any other document approved for use as an alternative to the maintenance release for the purposes of regulation 49, or subregulation 43 (10); or
(ii) is applicable to the maintenance release by virtue of a direction given under regulation 44;
(d) any maintenance that is required to be carried out before the commencement of the flight, or that will be required to be carried out before the expiration of the flight, to comply with any requirement or condition imposed under these regulations with respect to the aircraft has been certified, in accordance with regulation 42ZE or 42ZN, to have been completed;
AND (from CAR49)
Permissible unserviceabilities to be endorsed on maintenance releases
(1) This regulation applies to each of the following persons in relation to an aircraft in respect of which a maintenance release is in force:
(a) the holder of the certificate of registration for the aircraft;
(b) the operator of the aircraft;
(c) a flight crew member of the aircraft;
(d) a person who is permitted by regulation 42ZC or 42ZD to carry out maintenance on the aircraft.
(2) If:
(a) an aircraft in respect of which a maintenance release is in force has developed a defect, or has suffered damage, that is a permissible unserviceability; and
(b) there is a likelihood that the aircraft will be flown before the permissible unserviceability is rectified;
a person mentioned in subregulation (1), who becomes aware of the defect or damage, must endorse the maintenance release, or other document approved for use as an alternative to the maintenance release for the purposes of this regulation, in the manner set out in subregulation (3).
Penalty: 25 penalty units.
(3) For subregulation (2), the maintenance release or other document must be signed by the person mentioned in subregulation (1), and must:
(a) set out each permissible unserviceability that exists with respect to the aircraft; and
(b) set out the conditions (if any) with respect to the use of the aircraft with those permissible unserviceabilities set out in any direction given under regulation 37 in relation to those permissible unserviceabilities as are not set out in any operations manual issued with respect to the aircraft or in Part 20 of the Civil Aviation Orders; and
(c) state that the maintenance release has effect subject to those conditions, whether set out in the maintenance release or the other document or otherwise.
Thus, if you endorse a maintenance release with a minor (MEL acceptable or otherwise minor) defect and indicate that there are no conditions imposed by this defect the aircraft may be flown.
CAR 50 covers major defects which should ground the aircraft, however the law surrounding the MR is that you must provide an endorsement to notify the registered operator and any pilots likely to fly the aircraft. The PIC then makes a decision as to whether the to fly with the defect, get LAME advice or not fly. Different pilots may make different decisions (EG: blown landing light may be a no go for a pilot doing night flights but acceptable to one intending a daylight only flight).
Either way unless the MR is actually endorsed with "not to be flown" (a condition) or similar it is NOT grounded. The only exception to this (under CAR 133D above) is if maintenance is required under legislation (Eg: AD's)
Thread Starter
601 qnd Lostwingnut:
Perhaps wrong and double wrong. Section 8 in bold. CAAP 42ZC-1(2) refers.
By definition the Pilot is capable of fixing, or making temporary repairs to, or deciding not to fix "a ripped cabin liner". Whether he needs to write it up as a defect then fix it himself and endorse the MR is another question. I would have though a small rip in a liner or suchlike was fair wear
Quote:
I know of an AWI that pinged a poor 300 hour pilot for having a ripped roof lining. It was not hanging down or obstructing the cabin, just a small rip probably cause by a fishing rod or something similar. The AWI made it very clear that it was a defect and needed to be endorsed on the MR.
Correctly so. If it was not on the MR how would anyone know it required repair.
I know of an AWI that pinged a poor 300 hour pilot for having a ripped roof lining. It was not hanging down or obstructing the cabin, just a small rip probably cause by a fishing rod or something similar. The AWI made it very clear that it was a defect and needed to be endorsed on the MR.
Correctly so. If it was not on the MR how would anyone know it required repair.
Perhaps wrong and double wrong. Section 8 in bold. CAAP 42ZC-1(2) refers.
By definition the Pilot is capable of fixing, or making temporary repairs to, or deciding not to fix "a ripped cabin liner". Whether he needs to write it up as a defect then fix it himself and endorse the MR is another question. I would have though a small rip in a liner or suchlike was fair wear
3
.
Copy of Schedule 8 of CAR 1988
Schedule 8 Maintenance that may be carried out on a c
lass B aircraft by a pilot entitled to do so under subregulation 42ZC(4)
(subregulation 42ZC (4))
1.Removal or installation of landing gear tyres, but only if the removal or installation does
not involve the complete jacking of the aircraft.
2.Repair of pneumatic tubes of landing gear tyres.
3.Servicing ofl anding gear wheel bearings.
4.Replacement of defective safety wiring or split pins, but not including wiring or pins in
control systems.
5.Removal or refitting of a door, but only if:
(a)no disassembly of the primary structure or operating system
of the aircraft is involved; and
(b)if the aircraft is to be operated with the door removed —the aircraft has a flight
manual and the manual indicates that the aircraft may be operated with the door
removed.
6.Replacement of side windows in an unpressurised aircraft.
7.Replacement of seats, but only if the replacement does not involve disassembly of any part of the primary structure of the aircraft.
8.Repairs to the upholstery or decorative furnishings of the interior of the cabin or cockpit.
9 Replacement of seat belts or harnesses.
10.Replacement or repair of signs and markings.
11.Replacement of bulbs, reflectors, glasses, lenses or lights.
12.Replacement, cleaning, or setting gaps of spark plugs.
13.Replacement of batteries.
14.Changing oil filters or air filters.
15.Changing or replenishing engine oil or fuel.
16.Lubrication not requiring disassembly or requiring only the removal of non structural parts, or of cover plates, cowlings and fairings.
17.Replenishment of hydraulic fluid.
18.Application of preservative or protective materials, but only if no disassembly of the
primary structure or operating system of the aircraft is involved.
19.Removal or replacement of equipment used for agricultural purposes.
20.Removal or replacement of glider tow hooks.
21. Carrying out of an inspection under regulation 42G of a flight control system that has been assembled, adjusted,repaired, modified or replaced.
22. Carrying out of a daily inspection of an aircraft.
.
Copy of Schedule 8 of CAR 1988
Schedule 8 Maintenance that may be carried out on a c
lass B aircraft by a pilot entitled to do so under subregulation 42ZC(4)
(subregulation 42ZC (4))
1.Removal or installation of landing gear tyres, but only if the removal or installation does
not involve the complete jacking of the aircraft.
2.Repair of pneumatic tubes of landing gear tyres.
3.Servicing ofl anding gear wheel bearings.
4.Replacement of defective safety wiring or split pins, but not including wiring or pins in
control systems.
5.Removal or refitting of a door, but only if:
(a)no disassembly of the primary structure or operating system
of the aircraft is involved; and
(b)if the aircraft is to be operated with the door removed —the aircraft has a flight
manual and the manual indicates that the aircraft may be operated with the door
removed.
6.Replacement of side windows in an unpressurised aircraft.
7.Replacement of seats, but only if the replacement does not involve disassembly of any part of the primary structure of the aircraft.
8.Repairs to the upholstery or decorative furnishings of the interior of the cabin or cockpit.
9 Replacement of seat belts or harnesses.
10.Replacement or repair of signs and markings.
11.Replacement of bulbs, reflectors, glasses, lenses or lights.
12.Replacement, cleaning, or setting gaps of spark plugs.
13.Replacement of batteries.
14.Changing oil filters or air filters.
15.Changing or replenishing engine oil or fuel.
16.Lubrication not requiring disassembly or requiring only the removal of non structural parts, or of cover plates, cowlings and fairings.
17.Replenishment of hydraulic fluid.
18.Application of preservative or protective materials, but only if no disassembly of the
primary structure or operating system of the aircraft is involved.
19.Removal or replacement of equipment used for agricultural purposes.
20.Removal or replacement of glider tow hooks.
21. Carrying out of an inspection under regulation 42G of a flight control system that has been assembled, adjusted,repaired, modified or replaced.
22. Carrying out of a daily inspection of an aircraft.
Last edited by Sunfish; 21st Mar 2013 at 08:30.
8.Repairs to the upholstery or decorative furnishings of the interior of the cabin or cockpit.
It is a defect, therefore endorse the MR.
Now we have two options;
1. If the defect is not endorsed "aircraft not airworthy" (CAR 47) the aircraft can be flown back to maintenance.
or
2. If the pilot has the knowledge and tools to repair the defect
Under Schedule 8, a pilot can repair it.
As the pilot has conducted the maintenance, the pilot signs, dates and inserts his/her ACN certifying that maintenance has been done.
601, I don't follow the reference? Can you elaborate?
Last edited by 601; 21st Mar 2013 at 00:01.
Unfortunately CASA don't see that way. I have seen FOI's ground aircraft over minor defects which had no bearing on the safety or the integrity of the aircraft. Their view is that if their is any defect on the aircraft at all no matter how small or irrelevent you have to endorse the MR and if it cannot be closed off by deferral to DDG, by a LAME, a PUS or approved pilot maintenance then the aircraft is unairworthy. You cannot fly aircraft around with open defects on the MR no matter how irrelevent they are.
And despite the argument to the FOI that the offending part was only for comestic purposes the FOI still grounded the aircraft.
THAT is what you are dealing with.
So you can quote the CARs till the cows come home but unless you take CASA to court and get a ruling nothing will change.
And despite the argument to the FOI that the offending part was only for comestic purposes the FOI still grounded the aircraft.
THAT is what you are dealing with.
So you can quote the CARs till the cows come home but unless you take CASA to court and get a ruling nothing will change.
Last edited by neville_nobody; 21st Mar 2013 at 01:14.
I have seen FOI's ground aircraft over minor defects which had no bearing on the safety or the integrity of the aircraft. Their view is that if their is any defect on the aircraft at all no matter how small or irrelevent you have to endorse the MR and if it cannot be closed off by deferral to DDG, by a LAME, a PUS or approved pilot maintenance then the aircraft is unairworthy. You cannot fly aircraft around with open defects on the MR no matter how irrelevent they are.
As FOIs and AWIs come from the industry (mostly), some have ingrain incorrect ideas about this subject.
Education is the answer.
If CASA is following this thread, they should have detected a lack of understanding on this subject and produce some education material for the industry and for the staff of CASA so we are all singing from the same page.
But getting an consistent interpretation on a subject from CASA can take an eternity. I have questions put in writing to CASA over 5 years old that are still unanswered.
One only had to follow the sad saga about aerial baiting.
We used to have a great forum at AF every three months where we could get strait answers. Sadly these days have passed.
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casa and Honesty!!
The unfortunate part of this is that there is no consistency in how either an AWI or a FOI answer a question. These people are supposed to be the experts, yet consistently I have seen these people having difficulties in answering even what are simple questions.
I am sure that the parlous state of the regulations does not help this situation. The rate of change that is being forced on the industry of what are now very complex regulations.
This will not make the way forward easy at all and those who should be able to assist the industry seem to be doing everything possible to ensure that the industry does not go forward.
This is not assisted by an executive who is devious and does things that are aimed at protecting themselves, not progressing the industry. The dis-connect between industry and casa is getting greater and greater.
The discussion in this thread indicates the issues - in a Maintenance Release situation. It can be extended to other threads [see Barrier (http://www.pprune.org/pacific-genera...-drift-13.htm) and Hardy's.]
The problem here is such that pilots, who have read the material provided by casa or by the owner or the operator are confused.
I have been an owner and have been told a range of answers to the same question by the AWI, FOI, ATO, other pilots etc.
It points simply to the problem of people having to "interpret" regs, MR's, opinions and listen to "directions" from owners or the LAME. It only gets more complex when someone is directed to bring an aircraft home.
Read the example of Dennis Grosser which goes back to 2003 at Denis's trial - outcome and action.*
In part this says:
and the notice to the pilot:
Notice from CASA to Denis Grosser to surrender licences, logbooks, and maintenance releases
We must see this all stop, particularly with the issue of "Strict Liability" and the ability of casa to "nail" you.
I am sure that the parlous state of the regulations does not help this situation. The rate of change that is being forced on the industry of what are now very complex regulations.
This will not make the way forward easy at all and those who should be able to assist the industry seem to be doing everything possible to ensure that the industry does not go forward.
This is not assisted by an executive who is devious and does things that are aimed at protecting themselves, not progressing the industry. The dis-connect between industry and casa is getting greater and greater.
The discussion in this thread indicates the issues - in a Maintenance Release situation. It can be extended to other threads [see Barrier (http://www.pprune.org/pacific-genera...-drift-13.htm) and Hardy's.]
The problem here is such that pilots, who have read the material provided by casa or by the owner or the operator are confused.
I have been an owner and have been told a range of answers to the same question by the AWI, FOI, ATO, other pilots etc.
It points simply to the problem of people having to "interpret" regs, MR's, opinions and listen to "directions" from owners or the LAME. It only gets more complex when someone is directed to bring an aircraft home.
Read the example of Dennis Grosser which goes back to 2003 at Denis's trial - outcome and action.*
In part this says:
If Denis had not sought CASA out and asked for advice, none of this would have happened. His co-operation brought him down. He co-operated in Birdsville. He co-operated by sending back the ASR. He co-operated by handing over his logbook. He co-operated by going to the AAT (as CASA suggested). Once in the AAT he co-operated with CASA's cross-examination of him. Every single piece of that co-operation harmed him.
You might wonder why Denis went to such lengths to engineer his own downfall. I think it was because he misunderstood the legislation under which CASA operates. Denis is a farmer and a machinery dealer. I too am a farmer (of sorts). When I have a problem with weeds, I call the local weeds officer. When I have a problem with erosion, I call the Soil Conservation officer. When I have a problem with pastures, I call the Department of Agriculture. No doubt Denis does likewise. I know full well that the Weeds Officer has power to prosecute me in Court if I fail to control noxious weeds. But I also know that the Court won't punish me unless I actually do something that is against the law. Having received his advice I am free to follow it or not, as I choose. If the weeds officer thinks I should use spray to control the blackberries, for example, and I choose to use feral goats instead, that's fine. The weeds officer has no power to impose his opinion on mine, and it would be unthinkable that the weeds officer could unilaterally cancel my farming license.
But the aviation law is entirely different. Australia's aviation law is extremely punitive, and it gives CASA officers immense powers to impose their own opinion on others - and they are protected from responsibility for the outcome. I don't think Denis had the slightest suspicion that the aviation law was so un-Australian. I know that if you have an aviation problem, the LAST thing you do is call CASA because CASA officers can and do unilaterally cancel pilots' licenses if there is a difference of opinion. But I suspect Denis did not know that.
So Denis flew his aircraft back to Horsham solo, with the gear down all the way, quite uneventfully. He was so innocent, in his own mind, that he wrote the flight in his logbook!
You might wonder why Denis went to such lengths to engineer his own downfall. I think it was because he misunderstood the legislation under which CASA operates. Denis is a farmer and a machinery dealer. I too am a farmer (of sorts). When I have a problem with weeds, I call the local weeds officer. When I have a problem with erosion, I call the Soil Conservation officer. When I have a problem with pastures, I call the Department of Agriculture. No doubt Denis does likewise. I know full well that the Weeds Officer has power to prosecute me in Court if I fail to control noxious weeds. But I also know that the Court won't punish me unless I actually do something that is against the law. Having received his advice I am free to follow it or not, as I choose. If the weeds officer thinks I should use spray to control the blackberries, for example, and I choose to use feral goats instead, that's fine. The weeds officer has no power to impose his opinion on mine, and it would be unthinkable that the weeds officer could unilaterally cancel my farming license.
But the aviation law is entirely different. Australia's aviation law is extremely punitive, and it gives CASA officers immense powers to impose their own opinion on others - and they are protected from responsibility for the outcome. I don't think Denis had the slightest suspicion that the aviation law was so un-Australian. I know that if you have an aviation problem, the LAST thing you do is call CASA because CASA officers can and do unilaterally cancel pilots' licenses if there is a difference of opinion. But I suspect Denis did not know that.
So Denis flew his aircraft back to Horsham solo, with the gear down all the way, quite uneventfully. He was so innocent, in his own mind, that he wrote the flight in his logbook!
Notice from CASA to Denis Grosser to surrender licences, logbooks, and maintenance releases
We must see this all stop, particularly with the issue of "Strict Liability" and the ability of casa to "nail" you.
Last edited by Up-into-the-air; 21st Mar 2013 at 06:43. Reason: missed something
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I'm rapidly falling out of love with aviation ...
Come on now, little fish swim on up to the Sun and come for a cruise in our little flying boat. That'll put the love of aviation back into you!
Your Seaplane leaves from golden beach,
And paradise is within you reach.
For gently we shall rise above,
Lifted on these wings of love!
- Weloveseaplanes.
And paradise is within you reach.
For gently we shall rise above,
Lifted on these wings of love!
- Weloveseaplanes.
Last edited by weloveseaplanes; 21st Mar 2013 at 10:17.