Magneto calendar overhauls - the thin end of the wedge?
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SB643B is not even a 'mandatory' SB. It is marked 'compliance will enhance safety'. So will having your appendix prophylactically removed, along with that of your wife and all of your children, at birth. Doing so will enhance safety. It must. Anyone who thinks otherwise is a danger to themselves.
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"Are you suggesting that the only way LAME shops are going to survive is by doing more unnecessary maintenance?"
Not at all, my point being, there is plenty of scope to carry out maintenance as its required without going over the top, so long as it stays within the bounds
Of the Reg's as they stand. The hours to incorporate the annuals etc haven't changed, but the overheads have increased massively. Hence the hourly rate
Has to change to keep the status quo.
What I do have a problem with, is data that showed historically, for instance vac pumps, on average failing around 600hrs, and having some advocate to not change them until they fail, cause you should be right on the backups etc!
I have a problem with the idea of maintained to failure. I also have a problem with over maintaining and owners being taken for a ride.
Take the proposed Prop AD that might revert to manufacturers periods.
Some say it's over the top, but what climate is the aircraft stored in, how is it used/abused, how much is it used, is it hangared, on a pad, on grass, everyone's experience is different, (SIDS accounts a little for this)component manufacturers have to set a time line to account for all variables obviously, I might think as it lives in wilcannia the calendar shouldn't count due to dry environment, but I still have to abide by the Reg's.
Forgetting the SB for a moment, In my experience, with what is found from time to time in mags for instance inspected on calendar time, it is worth doing.
I would prefer a major inspection style system implemented, but that's for another thread.
Not at all, my point being, there is plenty of scope to carry out maintenance as its required without going over the top, so long as it stays within the bounds
Of the Reg's as they stand. The hours to incorporate the annuals etc haven't changed, but the overheads have increased massively. Hence the hourly rate
Has to change to keep the status quo.
What I do have a problem with, is data that showed historically, for instance vac pumps, on average failing around 600hrs, and having some advocate to not change them until they fail, cause you should be right on the backups etc!
I have a problem with the idea of maintained to failure. I also have a problem with over maintaining and owners being taken for a ride.
Take the proposed Prop AD that might revert to manufacturers periods.
Some say it's over the top, but what climate is the aircraft stored in, how is it used/abused, how much is it used, is it hangared, on a pad, on grass, everyone's experience is different, (SIDS accounts a little for this)component manufacturers have to set a time line to account for all variables obviously, I might think as it lives in wilcannia the calendar shouldn't count due to dry environment, but I still have to abide by the Reg's.
Forgetting the SB for a moment, In my experience, with what is found from time to time in mags for instance inspected on calendar time, it is worth doing.
I would prefer a major inspection style system implemented, but that's for another thread.
Magneto Overhaul
I am going to throw a spanner in the works and say that CASA in fact endorse in their own regulations the on condition operation of engine components where correct condition monitoring has taken place.
It works like this ADs it above all other documents in the CASA hierarchy (therefore an AD overrides contradictory statements from AMM, Engine overhaul and component overhaul manuals.
For private owners AD ENG 4 states:
To ensure the continuing airworthiness of the engine, and those components necessary for the operation of the engine, in addition to the requirements of Schedule 5 of the Civil Aviation Regulations; carry out the maintenance actions detailed in Appendix A of this Airworthiness Directive (AD).
Requirement A1:
Carry out an engine performance run to determine the engine performance in accordance with approved data. For turbocharged / supercharged engines, the output parameters shall be adjusted in accordance with manufacturer’s data.
Record engine and aircraft details and parameters achieved during the engine run on “Piston Engine Condition Report” (CASA Form 728) or an equivalent form. All completed forms shall be part of the
engine maintenance record.
The above from the AD overrides the manufacturers requirement to do hard life overhaul.
This is also supported by AWB02-1:
Manufacturers Recommended TBO
Aircraft and component manufacturers can make "Hard Time" recommendations (i.e. removal of items from service at a specified period for overhaul or replacement indifferent of the items current performance condition), usually referred to as Time Between Overhaul (TBO), which specify how long they consider their product should remain in service. These recommendations are based on average utilisation and conditions and usually recommend that the item be fully stripped and returned to the original specifications. TBO's do not normally involve a condition check being done during the items life. The ability to escalate these hard time limitations however, comes from effective condition monitoring - the real basis for "on-condition" maintenance.
CASA Recommendations
C of R holders should utilise the philosophy of "on-condition" maintenance to detect the onset of failures of such items, particularly when time in-service of these items are in the vicinity of the manufacturer's recommended TBO.
Provided that a component continues to meet the documented standard, at the appropriate frequencies, it is considered satisfactory to remain in service. TBOs that are not included in the manufacturers Airworthiness Limitations or in Airworthiness Directives issued by CASA should still be considered, unless substantiation has been collated to show the outcome of "on-condition" inspections are still appropriate for the safe operation of the aircraft or equipment.
Where alleviation is permitted beyond the manufacturer's TBO, an example of which would be AD/ENG/4, C of R holders and LAME's must ensure at the completion of the aircraft periodic inspection the "on-condition" maintenance inspection requirements are included on part 1 of the aircrafts maintenance release as "maintenance required".
The hole point of the private section of AD/ENG 4 was to override hard time overhaul limits: See here
www.casa.gov.au/newrules/parts/039/download/ris9802.pdf
It works like this ADs it above all other documents in the CASA hierarchy (therefore an AD overrides contradictory statements from AMM, Engine overhaul and component overhaul manuals.
For private owners AD ENG 4 states:
To ensure the continuing airworthiness of the engine, and those components necessary for the operation of the engine, in addition to the requirements of Schedule 5 of the Civil Aviation Regulations; carry out the maintenance actions detailed in Appendix A of this Airworthiness Directive (AD).
Requirement A1:
Carry out an engine performance run to determine the engine performance in accordance with approved data. For turbocharged / supercharged engines, the output parameters shall be adjusted in accordance with manufacturer’s data.
Record engine and aircraft details and parameters achieved during the engine run on “Piston Engine Condition Report” (CASA Form 728) or an equivalent form. All completed forms shall be part of the
engine maintenance record.
The above from the AD overrides the manufacturers requirement to do hard life overhaul.
This is also supported by AWB02-1:
Manufacturers Recommended TBO
Aircraft and component manufacturers can make "Hard Time" recommendations (i.e. removal of items from service at a specified period for overhaul or replacement indifferent of the items current performance condition), usually referred to as Time Between Overhaul (TBO), which specify how long they consider their product should remain in service. These recommendations are based on average utilisation and conditions and usually recommend that the item be fully stripped and returned to the original specifications. TBO's do not normally involve a condition check being done during the items life. The ability to escalate these hard time limitations however, comes from effective condition monitoring - the real basis for "on-condition" maintenance.
CASA Recommendations
C of R holders should utilise the philosophy of "on-condition" maintenance to detect the onset of failures of such items, particularly when time in-service of these items are in the vicinity of the manufacturer's recommended TBO.
Provided that a component continues to meet the documented standard, at the appropriate frequencies, it is considered satisfactory to remain in service. TBOs that are not included in the manufacturers Airworthiness Limitations or in Airworthiness Directives issued by CASA should still be considered, unless substantiation has been collated to show the outcome of "on-condition" inspections are still appropriate for the safe operation of the aircraft or equipment.
Where alleviation is permitted beyond the manufacturer's TBO, an example of which would be AD/ENG/4, C of R holders and LAME's must ensure at the completion of the aircraft periodic inspection the "on-condition" maintenance inspection requirements are included on part 1 of the aircrafts maintenance release as "maintenance required".
The hole point of the private section of AD/ENG 4 was to override hard time overhaul limits: See here
www.casa.gov.au/newrules/parts/039/download/ris9802.pdf
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And I agree with everything you just said. I agree that it would be sensible to mandate replacement of a vacuum pump at 600 hours in IFR cat and without a second attitude gyro (not a T&B) powered independently. That would be sensible. Overhauling all 4 of my magnetos every 4 years is not. If one fails in flight, I just get to look at my engine monitor, switch the magneto off and continue to my destination. I have 3 others (which get inspected every 500 hours because it is a good, sensible idea), and a whole spare engine. Where is the risk?
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Brainy.
"SB643B is not even a 'mandatory' SB. It is marked 'compliance will enhance safety'"
So why even do the 500hrly then!? It's the same SB.
It also said,
"magnetos MUST be overhauled or replaced at the expiration of five years since the date of original manufacture or last overhaul, or four years since the date the magneto was placed in service,
Per the Reg's, The components must have an overhaul period, the SB sets out that period. Period.
"SB643B is not even a 'mandatory' SB. It is marked 'compliance will enhance safety'"
So why even do the 500hrly then!? It's the same SB.
It also said,
"magnetos MUST be overhauled or replaced at the expiration of five years since the date of original manufacture or last overhaul, or four years since the date the magneto was placed in service,
Per the Reg's, The components must have an overhaul period, the SB sets out that period. Period.
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Where's the risk!
Because not everyone's as good a pilot as you, and I can't change the rules to suit you, I have to comply with CASA's view, and when you sell the aircraft to someone else who does have that failure, they won't be as forgiving as you,
Nor the maintainer who then reports me to CASA,
Everyone does this internal risk assessment on the possible outcome of a failure of a component, would it be mad to let go on a single engine, but ok on a twin, would the back up instrument save me, would it cause a fuel leak, how bad, so many variables.
CASA stipulate when using Sched 5, manufacturers Data must be used and that includes components.
The manufacturers data includes all SB's ect. TCM have 5 categories of SB/SL etc. that are referred to.
When the SB states quite clearly, that mags MUST be done at 4 years, I do.
Again, everyone seems happy to do the 500hr, but omit the 4 yearly. It's
The same Doc.
Because not everyone's as good a pilot as you, and I can't change the rules to suit you, I have to comply with CASA's view, and when you sell the aircraft to someone else who does have that failure, they won't be as forgiving as you,
Nor the maintainer who then reports me to CASA,
Everyone does this internal risk assessment on the possible outcome of a failure of a component, would it be mad to let go on a single engine, but ok on a twin, would the back up instrument save me, would it cause a fuel leak, how bad, so many variables.
CASA stipulate when using Sched 5, manufacturers Data must be used and that includes components.
The manufacturers data includes all SB's ect. TCM have 5 categories of SB/SL etc. that are referred to.
When the SB states quite clearly, that mags MUST be done at 4 years, I do.
Again, everyone seems happy to do the 500hr, but omit the 4 yearly. It's
The same Doc.
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Exactly. It is not mandatory and 'You are responsible for assessing each service bulletin to determine whether it should be followed or adopted.' in CASA's own words. As to selling the aircraft, it is a piston twin - you can't give them away, so no danger there! 😜
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Ha, agreed.
Cirrus are the new Barron-Cessna 210.
Brainy. The Reg's quite explicitly lay down the manufacturers data is to be followed, along with Component overhaul requirements.
Within the SB referred to, it states in black and white, that Mags MUST....
If the Reg's are the first port of call. To me It goes something like this.
CASA Reg.
Aircraft maintenance Data is to be used for Maintenance.
Components must have a overhaul period.
In the MM, there will be a component overhaul schedule.
If not, you revert to the component manufacturer overhaul schedule.
In black and white, there are overhaul and inspection periods.
The Reg's say you must follow the Data, as its a CASA directive to follow the data, you then must follow the periods set out in the Data, especially when preceded by the word MUST.
This is how our surveyers and Reps state it.
This is also how I see it.
There is copious amounts of waffle and ambiguity within all of the common law pages, CASA Reg's, and advisories, but one thing that shines through is IF you are aware of overhaul periods, and there is not an explicit AD (AD/Eng4/AII) (ADProp/1) to allow an over run, then, as there is nothing saying you don't have to abide by the component periods, they must be adhered to.
Cirrus are the new Barron-Cessna 210.
Brainy. The Reg's quite explicitly lay down the manufacturers data is to be followed, along with Component overhaul requirements.
Within the SB referred to, it states in black and white, that Mags MUST....
If the Reg's are the first port of call. To me It goes something like this.
CASA Reg.
Aircraft maintenance Data is to be used for Maintenance.
Components must have a overhaul period.
In the MM, there will be a component overhaul schedule.
If not, you revert to the component manufacturer overhaul schedule.
In black and white, there are overhaul and inspection periods.
The Reg's say you must follow the Data, as its a CASA directive to follow the data, you then must follow the periods set out in the Data, especially when preceded by the word MUST.
This is how our surveyers and Reps state it.
This is also how I see it.
There is copious amounts of waffle and ambiguity within all of the common law pages, CASA Reg's, and advisories, but one thing that shines through is IF you are aware of overhaul periods, and there is not an explicit AD (AD/Eng4/AII) (ADProp/1) to allow an over run, then, as there is nothing saying you don't have to abide by the component periods, they must be adhered to.
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Waffle and Ambiguity indeed. It is near impossible to gain a clear, unambiguous position. Your take on it doesn't make it what is required by law, nor does mine. However, CASA have advised me, as the registered operator of the aircraft responsible for the continued airworthiness of that aircraft, that 'You are responsible for assessing each service bulletin to determine whether it should be followed or adopted'. I am almost as frustrated by this as I am by watching the Lions.
It all just strikes me as CASA getting the maintenance shops to do their dirty work for them. If they believe that magnetos MUST be overhauled every 4 yrs (only bendix ones by the way) because of a risk to airworthiness and safety, an AD should be issued, as compliance is then mandatory. In any case AD ENG 4 applies to 'engine and components necessary for the operation of the engine', so does that not apply to magnetos??
It all just strikes me as CASA getting the maintenance shops to do their dirty work for them. If they believe that magnetos MUST be overhauled every 4 yrs (only bendix ones by the way) because of a risk to airworthiness and safety, an AD should be issued, as compliance is then mandatory. In any case AD ENG 4 applies to 'engine and components necessary for the operation of the engine', so does that not apply to magnetos??
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I believe not.
That's my understanding, that it refers to the engine only.
do me a favor, read tcm sil99-2c.
How it was written in such a way was to appease one
Operator to give flexibility. So I was told by someone
Who used to work at TCM
That's my understanding, that it refers to the engine only.
do me a favor, read tcm sil99-2c.
How it was written in such a way was to appease one
Operator to give flexibility. So I was told by someone
Who used to work at TCM
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That's not fair, you're trying to bore me into submission now!
Where's the risk!
I'd be much more concerned about single vacuum failure on a dark and cloudy night, than a magneto problem.
There's only so much money to go around (remember affordable safety) so we should be spending it to get good benefit, not arse covering,
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Drpixie, hopefully you are referring to on condition maintenance which is carried out prior to failure. FWIW Perspective has the right perspective on the magneto overhaul question. Brainy, the OP, just doesn't like the answer.
A way around the issue is for Brainy to have a delegate write up an SOM which excludes magneto overhaul and get it approved.
A way around the issue is for Brainy to have a delegate write up an SOM which excludes magneto overhaul and get it approved.
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This $600 fee that is so talked about making out that the lame gets it is soooo wrong it's not funny.
Look at it like this.
Workshop gets prob on average 1 hour worth of work.
So then it's sent to an o/h shop that prob make $100 on it the rest is parts.
Great to see lame,s ripping everyone off.
But I guess it ok to take your Toyota for a service @ $150 an hour and that's ok.
Look at it like this.
Workshop gets prob on average 1 hour worth of work.
So then it's sent to an o/h shop that prob make $100 on it the rest is parts.
Great to see lame,s ripping everyone off.
But I guess it ok to take your Toyota for a service @ $150 an hour and that's ok.
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Well said Yr Right. It takes about an hour to R and R a magneto including adjust internal timing replace points etc. Current hourly pay for a LAME is approx $45, workshop charge out between 120$ and 130$ depending on location. Can't see $600 in there
Magneto Overhaul
Perspective - I'm not sure why you believe magnetos are not covered under the description "components necessary for the operation of the engine" in AD/ENG/4: the magnetos are required for the engines operation, are always included in engine overhaul manuals and supplied by the engine manufacturer.
In addition CASA regularly uses the term "components necessary for the operation of the engine" in other documents referring to engine components including the mags, carbi, turbocharger (where it comes with the engine) but not governor, alternator etc.
Even CASA would be hard pressed to argue that the mag is not required fro engine operation.
In addition CASA regularly uses the term "components necessary for the operation of the engine" in other documents referring to engine components including the mags, carbi, turbocharger (where it comes with the engine) but not governor, alternator etc.
Even CASA would be hard pressed to argue that the mag is not required fro engine operation.
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Hi Progressive,
The question was,
"In any case AD ENG 4 applies to 'engine and components necessary for the operation of the engine', so does that not apply to magnetos??""
AD/Eng/4 states, under applicability,
"Piston engines and those components necessary for the operation of the engine, installed in aeroplanes maintained in accordance with Civil Aviation Regulation CAR 42B CASA Maintenance Schedule.",
Requirement A4,
"Note A2: AWB 85-4 “Aircraft Piston Engine Calendar Time Overhaul” provides guidelines for additional inspections related to the calendar time overhaul."
Within AWB 85-4,
"It is recommended that the following procedures are followed for engines that have exceeded the calendar time overhaul recommendations of the engine manufacturers. ALL PROCEDURES listed below, should be performed per approved data where applicable and IN CONJUNCTION with the condition checks per AD/ENG/4."
There are 10 procedures required in addition to those within AD/Eng4.
Procedure 4.5, Check electrical items such as magnetos, spark plugs and harnesses etc for corrosion and malfunction due to moisture ingress and deterioration.
So, AD/Eng/4 tells me carry out performance run on the engine, with additional procedures contained within AWB 85-004, and that all procedures listed, such as step (4.5) should be performed per approved Data IN CONJUNCTION with condition checks etc.
Approved Data relating to the Magnetos would be
TCM SB 643B, and as example S20/S-200 service manual X42002-3 Which notes,
"Magnetos are electro-mechanical devices that use rotating parts and are subject to the same service treatment, environmental conditions and wear as the engine."
Then goes on to state about the 4 yearly inspection etc.
AD/Eng/4 and on to AWB 85-004, including SB 643B specifically talk about environmental conditions being a factor in continued service.
AWB 74-005 also states,
4. Recommendations
Follow manufacturers approved data for maintenance of magnetos. Magnetos operating in harsh environments or operating conditions should be overhauled more frequently than the recommended maintenance intervals....
So, in a nutshell,
AD/Eng/4, note A2 AWB 85-004
AWB 85-004 following procedures to be per approved Data.
4.5 check of electrical items such as magnetos for malfunction, moisture ingress and deterioration.
Approved data is SB643B and x42002-3 S-20 service manual amongst others.
Approved Data states 4 year's etc.
The question was,
"In any case AD ENG 4 applies to 'engine and components necessary for the operation of the engine', so does that not apply to magnetos??""
AD/Eng/4 states, under applicability,
"Piston engines and those components necessary for the operation of the engine, installed in aeroplanes maintained in accordance with Civil Aviation Regulation CAR 42B CASA Maintenance Schedule.",
Requirement A4,
"Note A2: AWB 85-4 “Aircraft Piston Engine Calendar Time Overhaul” provides guidelines for additional inspections related to the calendar time overhaul."
Within AWB 85-4,
"It is recommended that the following procedures are followed for engines that have exceeded the calendar time overhaul recommendations of the engine manufacturers. ALL PROCEDURES listed below, should be performed per approved data where applicable and IN CONJUNCTION with the condition checks per AD/ENG/4."
There are 10 procedures required in addition to those within AD/Eng4.
Procedure 4.5, Check electrical items such as magnetos, spark plugs and harnesses etc for corrosion and malfunction due to moisture ingress and deterioration.
So, AD/Eng/4 tells me carry out performance run on the engine, with additional procedures contained within AWB 85-004, and that all procedures listed, such as step (4.5) should be performed per approved Data IN CONJUNCTION with condition checks etc.
Approved Data relating to the Magnetos would be
TCM SB 643B, and as example S20/S-200 service manual X42002-3 Which notes,
"Magnetos are electro-mechanical devices that use rotating parts and are subject to the same service treatment, environmental conditions and wear as the engine."
Then goes on to state about the 4 yearly inspection etc.
AD/Eng/4 and on to AWB 85-004, including SB 643B specifically talk about environmental conditions being a factor in continued service.
AWB 74-005 also states,
4. Recommendations
Follow manufacturers approved data for maintenance of magnetos. Magnetos operating in harsh environments or operating conditions should be overhauled more frequently than the recommended maintenance intervals....
So, in a nutshell,
AD/Eng/4, note A2 AWB 85-004
AWB 85-004 following procedures to be per approved Data.
4.5 check of electrical items such as magnetos for malfunction, moisture ingress and deterioration.
Approved data is SB643B and x42002-3 S-20 service manual amongst others.
Approved Data states 4 year's etc.
Last edited by Perspective; 31st May 2015 at 18:05.
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Which brings us back to the fact that (as per CASA's maintenance guide for owner / operators) "the safety recommendations in an AWB are not mandatory...", so the advice I am being given that I HAVE NO OPTION but to comply with an overhaul of the magnetos on my left engine, which were removed, dismantled, inspected and had parts replaced 130hrs and 1 year ago, is not true. I have not been convinced otherwise.
My issue is solely with the fact that I am advised that CASA has mandated this action, but the fact is that they have not. They may tell the maintenance shops otherwise, but in the absence of an AD requiring action, all of the regs listed above remain advisory in nature.
My issue is solely with the fact that I am advised that CASA has mandated this action, but the fact is that they have not. They may tell the maintenance shops otherwise, but in the absence of an AD requiring action, all of the regs listed above remain advisory in nature.
Last edited by Brainy; 31st May 2015 at 20:29.