Views on CASA Schedule 5
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Views on CASA Schedule 5
Hi all,
New to the page and I am currently completing my University thesis on an evaluation of the maintenance schedules and regulations within Australia. I'm fairly new to the light aircraft scene so please excuse my somewhat lack of expertise on the topic, but I am here to learn!
Back to my question, I was wondering what everyone's opinions were on the current regulations and any current issues, especially regarding Schedule 5 and they way maintenance is managed and enforced.
Feel free to write as long as a response as you like, the more information the better as I am interested to hear your views and reasoning in detail.
Thanks you in advance for you help and i look forward to hearing from you all!
Steven.
New to the page and I am currently completing my University thesis on an evaluation of the maintenance schedules and regulations within Australia. I'm fairly new to the light aircraft scene so please excuse my somewhat lack of expertise on the topic, but I am here to learn!
Back to my question, I was wondering what everyone's opinions were on the current regulations and any current issues, especially regarding Schedule 5 and they way maintenance is managed and enforced.
Feel free to write as long as a response as you like, the more information the better as I am interested to hear your views and reasoning in detail.
Thanks you in advance for you help and i look forward to hearing from you all!
Steven.
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The worst and most expensive debacle to ever occur in the history of subordinate legislation around the English-speaking world?
A mish-mash of old and some new built on a philosophical foundation of retribution for any perceived breach of the provisions where not just intention is ruled out as a defence, but possibly also that of an honest and reasonable mistake?
All wrapped up in the abrogation of basic legal rights ordinarily pertaining in a civilised society, not by Act of Parliament, but by Executive decisions.
Kaz
A mish-mash of old and some new built on a philosophical foundation of retribution for any perceived breach of the provisions where not just intention is ruled out as a defence, but possibly also that of an honest and reasonable mistake?
All wrapped up in the abrogation of basic legal rights ordinarily pertaining in a civilised society, not by Act of Parliament, but by Executive decisions.
Kaz
Last edited by kaz3g; 8th May 2014 at 22:25.
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Sched 5 was workable when the Aust ADs where invoiced ie AD hose 5 and alike but as usual knobs in casa to keep there jobs changing rules etc all the time to keep them self's employed.
Feel free to pm me if you like I have to work with what we be given on a daily basis
Cheers
Feel free to pm me if you like I have to work with what we be given on a daily basis
Cheers
In principle, you have to acknowledge that the manufacturers maintenance schedule is best.
The problem is that (in the case of light aircraft) the manufacturers created maintenance schedules for the US environment where following them is not mandatory. So, they were produced as a guide, not a mandate.
With 20/20 hindsight we can see that manufacturers schedules over maintain some components, skip others which should be included (hence Cessna SIDS) and has never been updated to consolidate AD's. It also does not take into account better material and quality of parts available now compared with 40 years ago.
This works in the US system where departures from the manufacturers schedule is allowed, the FAA credits A&P mechanics with having some brains and there is a network of FAA offices which are approachable.
Australia's military based, centralist, bureaucratic system that has a culture of not trusting the competence of pilots and engineers can't live without a mandated list.
Hence schedule 5 was born. I reckon it was written around the maintenance requirements of a Tiger moth. Its loose and not very prescriptive and can be quite inappropriate - but strict adherence to manufacturers schedules is expensive and frequently inappropriate. Schedule 5 is the only mechanism we have to allow an element of common sense freedom.
The problem is that (in the case of light aircraft) the manufacturers created maintenance schedules for the US environment where following them is not mandatory. So, they were produced as a guide, not a mandate.
With 20/20 hindsight we can see that manufacturers schedules over maintain some components, skip others which should be included (hence Cessna SIDS) and has never been updated to consolidate AD's. It also does not take into account better material and quality of parts available now compared with 40 years ago.
This works in the US system where departures from the manufacturers schedule is allowed, the FAA credits A&P mechanics with having some brains and there is a network of FAA offices which are approachable.
Australia's military based, centralist, bureaucratic system that has a culture of not trusting the competence of pilots and engineers can't live without a mandated list.
Hence schedule 5 was born. I reckon it was written around the maintenance requirements of a Tiger moth. Its loose and not very prescriptive and can be quite inappropriate - but strict adherence to manufacturers schedules is expensive and frequently inappropriate. Schedule 5 is the only mechanism we have to allow an element of common sense freedom.
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Schedule 5 or manufactures inspections are just the minimum that you look at. When you do a service you look at a whole lot more than is in the work sheet. At the end of the day it's a minimum and that's all. Casa won't to remove shed 5 and remove any liabitly that goes with it. If you places on manufactures then you must comply with what they call up. Like engine control changes at engine o/h etc
Cheers
Cheers
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Manufactures maintenance will make it very hard for all of us operating in the bush to survive the extra costs. The powers that be push for manufactures maintenance schedules seem to forget that we all don't have the luxury of having a LAME based at all outback strips.
A lot of aircraft are satellite based 2 - 3 hours from the main base. On Sched 5 we have the option of pilot maintenance for the 50 hourly(change oil and filters). This works well, we switch over aircraft for 100 hrlys burning up 4 - 6 hours of the MR on ferries. That's acceptable and acknowledged as part of the price of offering a regional and remote service.
If we go to MM or Cessna progressive schedule from what I understand, then we automatically start burning up 8 to 12% of the MR just in ferries alone as on Cessna MM certain parts of the current 100 hrly will need to be done on the 50 hrly and are not pilot maintenance items.
So CASA in their wisdom to reduce the aging fleets and recommending MM schedule with the new part 135 etc, will actually age the fleet in the bush quicker, increase our cost, (someone has to pay for the extra ferries) and drive us out of business.
The cost of having a full time LAME in the air running around doing 50 hourly's is cost prohibitive and realistically unworkable.
Another example of the bush copping a double whammy. Will outback stations and communities and tourists pay the extra. Well history shows us no. Look at the amount of work left in the bush compared to 30 years ago when it was affordable for everyone that was remote to fly. With this on top of SIDS and rising fuel costs think Outback Aviation is doomed unless a bit of common sense from the regulators prevails.
A lot of aircraft are satellite based 2 - 3 hours from the main base. On Sched 5 we have the option of pilot maintenance for the 50 hourly(change oil and filters). This works well, we switch over aircraft for 100 hrlys burning up 4 - 6 hours of the MR on ferries. That's acceptable and acknowledged as part of the price of offering a regional and remote service.
If we go to MM or Cessna progressive schedule from what I understand, then we automatically start burning up 8 to 12% of the MR just in ferries alone as on Cessna MM certain parts of the current 100 hrly will need to be done on the 50 hrly and are not pilot maintenance items.
So CASA in their wisdom to reduce the aging fleets and recommending MM schedule with the new part 135 etc, will actually age the fleet in the bush quicker, increase our cost, (someone has to pay for the extra ferries) and drive us out of business.
The cost of having a full time LAME in the air running around doing 50 hourly's is cost prohibitive and realistically unworkable.
Another example of the bush copping a double whammy. Will outback stations and communities and tourists pay the extra. Well history shows us no. Look at the amount of work left in the bush compared to 30 years ago when it was affordable for everyone that was remote to fly. With this on top of SIDS and rising fuel costs think Outback Aviation is doomed unless a bit of common sense from the regulators prevails.
Kaz,
I like your posts......
One of my favorites:
"I remember who sold out GA in this country... minister Anderson who gave our airports away to big business for peanuts on leases that the monkeys could have written.
And his mates and the next mob all failed to sort it when it all started to fall apart.
They are all the b....y same!
Kaz"
I like your posts......
One of my favorites:
"I remember who sold out GA in this country... minister Anderson who gave our airports away to big business for peanuts on leases that the monkeys could have written.
And his mates and the next mob all failed to sort it when it all started to fall apart.
They are all the b....y same!
Kaz"
Last edited by ramble on; 9th May 2014 at 08:34.
Folks,
Schedule 5 would be the ideal maintenance schedule, if it was allowed to operate as intended.
If you have a knowledge of the design and certification standards of the FAA, including continuing airworthiness requirements, you would know how the US system works, and the Australian system was supposed to, but hasn't worked.
Schedule 5 IS FAR 43, Appendix D, (except for some added AU bullsh1t) an entirely comprehensive Inspection Schedule, it is NOT a system of maintenance, as the Schedule 5 is miss-described.
If you are maintaining virtually any FAR 23 aircraft, operating under Part 91, it is Part 91 that describes the maintenance to be done, Part 43 says how to do it, and (in some cases) Part 145 will tell you where to do it.
If the same aircraft is operating under Part 135 (roughly Charter) there will be additional maintenance requirements, which will be carried out per. Part 43, including the Appendix D.
[As an aside, this is how the Cessna SIDs are not mandatory for Part 91, but are for Part 135 and up, but I am not going to go into the explanation here]
The OEM MM is most certainly not "the best". except for some relatively recent examples, FAR 23 (and earlier CAR 3 equivalents) assume the use of the FAA Annual Inspection Schedule ( Appendix D) will be carried out using acceptable (or authorised) data, which includes but is certainly NOT limited to OEM MM. The OEM MM is required by part 43, Appendix D, but it is only part of the suite of acceptable data.
Indeed, with the Australian misapplication of continuing airworthiness standards for most US built aircraft, the CASA list of deficient OEM MMs is increasing. Mostly they are NOT deficient at all, when they just form part of, but not nearly all the acceptable data needed to complete routine maintenance tasks and all but major repairs.
For may of you, if you are half way smart, you will have at least FAA AC 43.13A/B as CASA approved data in you CAR 30 manuals.
Indeed, in general terms, the OEM MM will only include model specific information, and assumes that all the necessary additional acceptable data to be used will be found in the AC library. Many of your will be familiar with the wealth of detail in FAA AC43.13A and AC 43.13B, and many more FAA publications that cover specific continuing airworthiness issues, that are common to most aircraft.
During the period Bruce Byron was CASA CEO, a instrument was raised, which allowed the whole FAA AC library ( and the equivalent from other NAA ) as CASA approved data, without the need for CASA approval for each CAR 30 workshop.
Needless to say, there was much resistance from bowels of CASA, it eliminated the "data approval industry" at a stroke, the present shower, unsurprisingly, have completely reversed to Byron/Vaughan reform, prohibiting the use of such worldwide acceptable data in Australia, without (expensive and long time delay) CASA approval.
Right now, CASA has no idea where it is going with future GA maintenance rules, but the "iron ring" is pushing Part 42/145 as it stands, a disaster in the making.
Tootle pip!!
Schedule 5 would be the ideal maintenance schedule, if it was allowed to operate as intended.
If you have a knowledge of the design and certification standards of the FAA, including continuing airworthiness requirements, you would know how the US system works, and the Australian system was supposed to, but hasn't worked.
Schedule 5 IS FAR 43, Appendix D, (except for some added AU bullsh1t) an entirely comprehensive Inspection Schedule, it is NOT a system of maintenance, as the Schedule 5 is miss-described.
If you are maintaining virtually any FAR 23 aircraft, operating under Part 91, it is Part 91 that describes the maintenance to be done, Part 43 says how to do it, and (in some cases) Part 145 will tell you where to do it.
If the same aircraft is operating under Part 135 (roughly Charter) there will be additional maintenance requirements, which will be carried out per. Part 43, including the Appendix D.
[As an aside, this is how the Cessna SIDs are not mandatory for Part 91, but are for Part 135 and up, but I am not going to go into the explanation here]
The OEM MM is most certainly not "the best". except for some relatively recent examples, FAR 23 (and earlier CAR 3 equivalents) assume the use of the FAA Annual Inspection Schedule ( Appendix D) will be carried out using acceptable (or authorised) data, which includes but is certainly NOT limited to OEM MM. The OEM MM is required by part 43, Appendix D, but it is only part of the suite of acceptable data.
Indeed, with the Australian misapplication of continuing airworthiness standards for most US built aircraft, the CASA list of deficient OEM MMs is increasing. Mostly they are NOT deficient at all, when they just form part of, but not nearly all the acceptable data needed to complete routine maintenance tasks and all but major repairs.
For may of you, if you are half way smart, you will have at least FAA AC 43.13A/B as CASA approved data in you CAR 30 manuals.
Indeed, in general terms, the OEM MM will only include model specific information, and assumes that all the necessary additional acceptable data to be used will be found in the AC library. Many of your will be familiar with the wealth of detail in FAA AC43.13A and AC 43.13B, and many more FAA publications that cover specific continuing airworthiness issues, that are common to most aircraft.
During the period Bruce Byron was CASA CEO, a instrument was raised, which allowed the whole FAA AC library ( and the equivalent from other NAA ) as CASA approved data, without the need for CASA approval for each CAR 30 workshop.
Needless to say, there was much resistance from bowels of CASA, it eliminated the "data approval industry" at a stroke, the present shower, unsurprisingly, have completely reversed to Byron/Vaughan reform, prohibiting the use of such worldwide acceptable data in Australia, without (expensive and long time delay) CASA approval.
Right now, CASA has no idea where it is going with future GA maintenance rules, but the "iron ring" is pushing Part 42/145 as it stands, a disaster in the making.
Tootle pip!!
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The work sheets for Sched 5 have been around forever even before it was called that. The intendant use was that is was for aircraft that didn't have a maintenance sched in the m/m. Its success has brought about its own undoing as everyone has adopted it as mainstream. That's why it has Ag floats aircon etc already listed. At the end of the day is just a guild to what has to be done its a minium amount of work that is required.
The addinion of what the manufacture calls up in chapter 5 for life components is what everyone is worried about
Now CASA don't wont that responsibility and will close the loop hole down for what of better words/
As for AC43 we always been able to use it if it was in the approved docs list in the M/M for the aircraft you where working on or if a repair was done via an EO by a car30 and he stated to use it.
When an aircraft is modified for its original state say a Raisebeck mods it come with its own M/M which is listed then on the LBS to carry out the maintenance IAW with it.
Now you can use the Manufactures sched and still do 50 hourlys all you have to do is change LBS.
cheers
The addinion of what the manufacture calls up in chapter 5 for life components is what everyone is worried about
Now CASA don't wont that responsibility and will close the loop hole down for what of better words/
As for AC43 we always been able to use it if it was in the approved docs list in the M/M for the aircraft you where working on or if a repair was done via an EO by a car30 and he stated to use it.
When an aircraft is modified for its original state say a Raisebeck mods it come with its own M/M which is listed then on the LBS to carry out the maintenance IAW with it.
Now you can use the Manufactures sched and still do 50 hourlys all you have to do is change LBS.
cheers
yr right,
Why don't you stop trying to teach people to suck eggs, and just read what is written. By your last post, if that is what you really think, your knowledge of both the legal and practical requirements of maintaining continuing airworthiness is seriously deficient --- not uncommon in the GA fraternity.
I suggest you catch up on some of the CASA AWB of recent times on the subject.
Then go actually read FAR 43, Appendix D, and compare it to Schedule 5.
As for "Schedule 5 worksheets", that does not comprise acceptable data (or as CASA likes to say- approved). It seems to me you are very open minded, the trouble is, it is open at both ends.
You are clearly a product of the Australian system, where whatever you have been taught is all you seem to know ---- that what you have been taught might be wrong (like your objections to LOP running engines) never occurs to you. As long as CASA says it, you accept it.
Whether you like it or not, instructions for the continuing airworthiness of FAA certified airworthiness are part of the certification of the aircraft --- there is a very strong legal line of thought that (particularly since mid-1998) most Australian (US built) light aircraft have an invalid C.of A, because they have not been maintained to the requirements of the original FAA Certificate of Airworthiness standards.
As I have said before, the the OEM MM forms part of the acceptable (approved) data for Schedule 5, it is NOT either/or --- indeed, the OEM MM is one of the documents that is automatically CASA "approved" ----- although I have no doubt of the story posted by cleartoenter, that is not the fault of Schedule 5, that is the fault of the ignorance of the aircraft "Registered Operator" and his/her LAME.
There is far more than AC 43.13A/B that you should be cognoscente of in maintaining FAA certified aircraft.
Tootle pip!!
PS: "Mandatory Service Bulletins" ?? An OEM service bulletin becomes mandatory when an NAA turns it into an AD. Remember, the Cessna SIDs are not SBs, they are included in the MM.
Why don't you stop trying to teach people to suck eggs, and just read what is written. By your last post, if that is what you really think, your knowledge of both the legal and practical requirements of maintaining continuing airworthiness is seriously deficient --- not uncommon in the GA fraternity.
I suggest you catch up on some of the CASA AWB of recent times on the subject.
Then go actually read FAR 43, Appendix D, and compare it to Schedule 5.
As for "Schedule 5 worksheets", that does not comprise acceptable data (or as CASA likes to say- approved). It seems to me you are very open minded, the trouble is, it is open at both ends.
You are clearly a product of the Australian system, where whatever you have been taught is all you seem to know ---- that what you have been taught might be wrong (like your objections to LOP running engines) never occurs to you. As long as CASA says it, you accept it.
Whether you like it or not, instructions for the continuing airworthiness of FAA certified airworthiness are part of the certification of the aircraft --- there is a very strong legal line of thought that (particularly since mid-1998) most Australian (US built) light aircraft have an invalid C.of A, because they have not been maintained to the requirements of the original FAA Certificate of Airworthiness standards.
As I have said before, the the OEM MM forms part of the acceptable (approved) data for Schedule 5, it is NOT either/or --- indeed, the OEM MM is one of the documents that is automatically CASA "approved" ----- although I have no doubt of the story posted by cleartoenter, that is not the fault of Schedule 5, that is the fault of the ignorance of the aircraft "Registered Operator" and his/her LAME.
There is far more than AC 43.13A/B that you should be cognoscente of in maintaining FAA certified aircraft.
Tootle pip!!
PS: "Mandatory Service Bulletins" ?? An OEM service bulletin becomes mandatory when an NAA turns it into an AD. Remember, the Cessna SIDs are not SBs, they are included in the MM.
Last edited by LeadSled; 9th May 2014 at 14:55. Reason: Add info.
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As Yr Right has intimated, the intent of schedule 5 was to detail the annual/100 hour inspection requirements for those aircraft with less than ideal OEM requirements. Most notably for elec/inst/radio categories.
It is to be read in conjunction with the OEM MM and other approved data including mandatory replacement and overhaul criteria.
It is to be read in conjunction with the OEM MM and other approved data including mandatory replacement and overhaul criteria.
Question: For an experimental I'm building I need to produce a maintenance scheme.
I have a draft MM from hte kit manufacturers website. I have AC 43 and of course MM for the engine.
What should I avoid? Common sense tells me I should use the draft MM in conjunction with AC 43 for the airframe, and the engine and propeller MMs. Additoins might be needed for autopilot servos and electric trim.
What am I missing?
I have a draft MM from hte kit manufacturers website. I have AC 43 and of course MM for the engine.
What should I avoid? Common sense tells me I should use the draft MM in conjunction with AC 43 for the airframe, and the engine and propeller MMs. Additoins might be needed for autopilot servos and electric trim.
What am I missing?
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Sunfish just write Maintenance IAW aircraft MM and Schedule 5.
Your SAAA maintainers course would have clearly articulated this.
Making your own is also very simple. Perhaps download one like a Jabiru one from their website and modify it. They really just are a checklist and rather generic. The important part is actually properly using it come 100 hourly time.
Your SAAA maintainers course would have clearly articulated this.
Making your own is also very simple. Perhaps download one like a Jabiru one from their website and modify it. They really just are a checklist and rather generic. The important part is actually properly using it come 100 hourly time.
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We'll leadsled if you do shed 5 and unless you have that you will so sb etc o your lbs you don't have to do them. However if you doing it iaw manufactures you have to. The only time a sb is mandated is if it was an AD but clearly your nose bleed must have covered you eyes from being up so high in your seat. And as for tell you to suck eggs maybe you should take some note or what a a low life spanner swinger is someone you can take note of.
Cheers
Cheers
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Once again you only have to do what is in your LBS. However if you wish to have your aircraft in charter cat and you have your lbs in sched 5 you will have to change it to manufactures insp and all that go along with that.
Think I'm wrong about SB we'll I think not I had a big win in court as an expert whiteness against casa on that very thing. Plus several other points of law that they said was law but wasn't.
Cheers
Think I'm wrong about SB we'll I think not I had a big win in court as an expert whiteness against casa on that very thing. Plus several other points of law that they said was law but wasn't.
Cheers
yr right,
About the only thing that can be reasonably comprehended from your semi-illiterate posts are that you have a less than adequate understanding of what current Australian law says on the maintenance of airworthiness of Australian aircraft.
Sadly, you are not the only one with such knowledge shortcomings.
Tootle pip!!
About the only thing that can be reasonably comprehended from your semi-illiterate posts are that you have a less than adequate understanding of what current Australian law says on the maintenance of airworthiness of Australian aircraft.
Sadly, you are not the only one with such knowledge shortcomings.
Tootle pip!!
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Leady
Go hope in your seat and read the lbs. That is what the maintenance has to be done to. Casa have a push on to change all the lbs to an higher standard. Now you ask me if I was a pilot now some time back so I'll ask you again. Are you an engineer. When was the last time you signed for work done by yourself. When did you last issue a M/R.
Cheers
And btw I done over casa in a law court on this very question so have you !!!!
Go hope in your seat and read the lbs. That is what the maintenance has to be done to. Casa have a push on to change all the lbs to an higher standard. Now you ask me if I was a pilot now some time back so I'll ask you again. Are you an engineer. When was the last time you signed for work done by yourself. When did you last issue a M/R.
Cheers
And btw I done over casa in a law court on this very question so have you !!!!
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Schedule 5 is "accepted" or approved data for maintenance of an aircraft, if that aircraft's log book statement stipulates such for the maintenance release inspection.
The log book statement includes election of operational category as well as maintenance category. There is also a statement about Airworthiness Directives and modifications applicable to the aircraft.
Part 1 and Part 2 of Schedule 5, as well as maintenance called up in the approved OEM data, (POH, maintenance manual, structural repair manual, modifications etc)and State of Origin Airworthiness Directives form part of the continuing airworthiness instructions for an aircraft.
Part 2 of Schedule 5 can work, but not in isolation.
The log book statement includes election of operational category as well as maintenance category. There is also a statement about Airworthiness Directives and modifications applicable to the aircraft.
Part 1 and Part 2 of Schedule 5, as well as maintenance called up in the approved OEM data, (POH, maintenance manual, structural repair manual, modifications etc)and State of Origin Airworthiness Directives form part of the continuing airworthiness instructions for an aircraft.
Part 2 of Schedule 5 can work, but not in isolation.
Last edited by No Hoper; 12th May 2014 at 08:27. Reason: syntax