Magneto calendar overhauls - the thin end of the wedge?
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I know what your saying, but you can't look at the process of AD's in isolation,
They aren't going to issue an AD for every individual component which are many
And varied, for every different aircraft type and component overhaul requirements therein, you might say, well then just issue an AD stating all components must be done I.a.w. The overhaul schedule,
but the requirements
Already Are that you must carry out maintenance I.a.w. The approved Data,
The MM already gives you the overhaul periods, and under schedule 5 it's stated the components must have an overhaul period.
Again, you can't say I'll do the 500hr, but not the calendar, that's picking and choosing, if the Doc gave you the option of one or the other, that's different.
What gets me, even if you fly maybe 50hrs a year, that's 5g in fuel alone,
20g over 4 years, hangarage might be 20G for the same period, 20G for insurance, (not to mention scheduled servicing) so your paying 60G over 4 years just with those 3 examples, and you can't budget $400 for a 4yr (IRAN) over 4 years for a Mag inspection?
They aren't going to issue an AD for every individual component which are many
And varied, for every different aircraft type and component overhaul requirements therein, you might say, well then just issue an AD stating all components must be done I.a.w. The overhaul schedule,
but the requirements
Already Are that you must carry out maintenance I.a.w. The approved Data,
The MM already gives you the overhaul periods, and under schedule 5 it's stated the components must have an overhaul period.
Again, you can't say I'll do the 500hr, but not the calendar, that's picking and choosing, if the Doc gave you the option of one or the other, that's different.
What gets me, even if you fly maybe 50hrs a year, that's 5g in fuel alone,
20g over 4 years, hangarage might be 20G for the same period, 20G for insurance, (not to mention scheduled servicing) so your paying 60G over 4 years just with those 3 examples, and you can't budget $400 for a 4yr (IRAN) over 4 years for a Mag inspection?
Last edited by Perspective; 1st Jun 2015 at 00:14.
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The money is not the issue. Jeez, flying a pressurised piston twin is a good way to sink buckets of money into GA. It is the principle of enforcement of things that don't arguably provide additional safety over what is currently done (by me in my own individual case), when they are by CASA's own instruments not enforceable. Where is the logical extension of this - no more on-condition running of engines (the majority of the fleet disappears), 6 yr prop overhauls, along with control cables, why not flap motors, Aux pumps, brake callipers, air-con blowers and goodness knows what else. It is regulation for regulation's sake and it is destroying GA. I can afford to overhaul my magnetos, it is not a big item. The question though is why should I, when it is not mandatory and they were stripped and inspected a year ago? Is it safer? Arguably, no. Could that money be spent on something that would have a greater safety benefit, or maybe spend it on actually flying the machine?
Is it raining broken magneto parts and smoking airframes? I think not. Pilots destroy far more aircraft than magnetos do.
I am not picking and choosing - I can elect to ignore the SB altogether, but recognise that a 500hr inspection is probably a wise idea and is cost-effective. I am not convinced that, if I do that, an additional overhaul every 4 years, is. After all, the ongoing airworthiness of the aircraft is the operator's responsibility and, so long as no rules are broken, it seems to me that the operator can legitimately choose to decline the calendar overhaul of their magnetos. Wise? Maybe not, maybe so. Legal? It would seem to be absolutely so.
Is it raining broken magneto parts and smoking airframes? I think not. Pilots destroy far more aircraft than magnetos do.
I am not picking and choosing - I can elect to ignore the SB altogether, but recognise that a 500hr inspection is probably a wise idea and is cost-effective. I am not convinced that, if I do that, an additional overhaul every 4 years, is. After all, the ongoing airworthiness of the aircraft is the operator's responsibility and, so long as no rules are broken, it seems to me that the operator can legitimately choose to decline the calendar overhaul of their magnetos. Wise? Maybe not, maybe so. Legal? It would seem to be absolutely so.
Last edited by Brainy; 31st May 2015 at 22:49.
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Unfortunately so. The LAME doing my annual has checked with CASA this morning to clarify our position and confirmed that compliance with calendar overhaul times is not mandatory at this stage. I doubt that will last though.
It is unfair for CASA to make the LAMEs the meat in the sandwich between CASA's 'position' (with complete lack of proper process) and the owners / operators. They (CASA) need to get their act together, legislate appropriately to their wishes and intended outcomes, and then communicate effectively. Not something that any of us are likely to see in our lifetimes I guess. One good thing though I suppose is that they seem to be trying to screw us all over on so many different fronts that it dilutes their effectiveness in doing any of them properly.
It is unfair for CASA to make the LAMEs the meat in the sandwich between CASA's 'position' (with complete lack of proper process) and the owners / operators. They (CASA) need to get their act together, legislate appropriately to their wishes and intended outcomes, and then communicate effectively. Not something that any of us are likely to see in our lifetimes I guess. One good thing though I suppose is that they seem to be trying to screw us all over on so many different fronts that it dilutes their effectiveness in doing any of them properly.
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I hear ya,
Interesting, not the first time I've heard contradictory information,
Maybe get that in writing, I know I'm going to.
So here we are, I've spoken to my Surveyor and the information is that the SB is created to inform of the
TBO and Inspection periods for the Component.
So I hear you, that because it doesn't say Mandatory Service Bulletin, its optional, Ok then, no probs,
lets look at the Bendix Overhaul Manual, which is part of the approved Data which is consistently referred to on numerous
occasions. As I think most people are now comfortable that the Sched 5 is a list of things to look at, and the Maintenance and Component
overhaul Manual is the Approved Data, what does the approved Data say,
Bendix Manual.
2. "General Overhaul," as specified in Section 7-2, must be performed at the same interval as engine overhaul, or in the event of severe environmental effects
(engine overspeeds, sudden stoppage or other unusual circumstances), or at the expiration of four years without regard
to accumulated engine operating hours since new or last overhaul.
This is from the approved Data, The SB Highlights what's in the Manual.
However you look at it, whether you refer to the SB or Component Manual, the requirements are the same.
Your LAME Would have had it drummed into him no Doubt that he must have the latest revision Data for the Aircraft he is Working on.
Within That are references to the Components and relevant component Manuals.
He may have also read in the Piper manual, where they point out the use of SB's and MSB's, where Piper consider all to be Mandatory!
Some Background info,
from Aviation Occurrence Investigation 200600001, section 1.18.5,
As well as
4.2.2 Airworthiness bulletins and advisories
Safety issue
Currently, Civil Aviation Advisory Publication (CAAP) 42B-1(0) and
Airworthiness Bulletin AWB 02-003 Issue 2, are ambiguous regarding required
inspection intervals for Private category aircraft airframe items. This may result in
the items being operated past the specified aircraft manufacturer’s inspection
interval.
When you look at the Common Law, outlining the application of Schedule 5,
2.6 In this Part:
general maintenance inspection means a regular inspection
and check of a class B aircraft, its systems and components
that:
(a) is required by the aircraft’s maintenance schedule to be
carried out at regular intervals;
The TCM Service bulletin is what's used to outline the TBO Period for the component, in this case a Bendix Mag,
Remember that,
The CASA maintenance schedule, which is Schedule 5 of the CARs, is
widely misunderstood. Many think it replaces and relaxes the manufacturer’s
maintenance schedule.
When using Schedule 5,
6. Periodic Inspection Schedule
6.1 The replacement or overhaul of time-lifed components required in an Airworthiness Limitations Section of the aeroplane’s maintenance manual and any special techniques required by the manufacturer or an Airworthiness
Directive are required to be complied with.
CAR 1988
(f) set out details of the approved maintenance data used to
carry out the maintenance;
I wait to see what I get back from Southern region, But I think I know the answer and am happy to PM you
the results.
Interesting, not the first time I've heard contradictory information,
Maybe get that in writing, I know I'm going to.
So here we are, I've spoken to my Surveyor and the information is that the SB is created to inform of the
TBO and Inspection periods for the Component.
So I hear you, that because it doesn't say Mandatory Service Bulletin, its optional, Ok then, no probs,
lets look at the Bendix Overhaul Manual, which is part of the approved Data which is consistently referred to on numerous
occasions. As I think most people are now comfortable that the Sched 5 is a list of things to look at, and the Maintenance and Component
overhaul Manual is the Approved Data, what does the approved Data say,
Bendix Manual.
2. "General Overhaul," as specified in Section 7-2, must be performed at the same interval as engine overhaul, or in the event of severe environmental effects
(engine overspeeds, sudden stoppage or other unusual circumstances), or at the expiration of four years without regard
to accumulated engine operating hours since new or last overhaul.
This is from the approved Data, The SB Highlights what's in the Manual.
However you look at it, whether you refer to the SB or Component Manual, the requirements are the same.
Your LAME Would have had it drummed into him no Doubt that he must have the latest revision Data for the Aircraft he is Working on.
Within That are references to the Components and relevant component Manuals.
He may have also read in the Piper manual, where they point out the use of SB's and MSB's, where Piper consider all to be Mandatory!
Some Background info,
from Aviation Occurrence Investigation 200600001, section 1.18.5,
As well as
4.2.2 Airworthiness bulletins and advisories
Safety issue
Currently, Civil Aviation Advisory Publication (CAAP) 42B-1(0) and
Airworthiness Bulletin AWB 02-003 Issue 2, are ambiguous regarding required
inspection intervals for Private category aircraft airframe items. This may result in
the items being operated past the specified aircraft manufacturer’s inspection
interval.
When you look at the Common Law, outlining the application of Schedule 5,
2.6 In this Part:
general maintenance inspection means a regular inspection
and check of a class B aircraft, its systems and components
that:
(a) is required by the aircraft’s maintenance schedule to be
carried out at regular intervals;
The TCM Service bulletin is what's used to outline the TBO Period for the component, in this case a Bendix Mag,
Remember that,
The CASA maintenance schedule, which is Schedule 5 of the CARs, is
widely misunderstood. Many think it replaces and relaxes the manufacturer’s
maintenance schedule.
When using Schedule 5,
6. Periodic Inspection Schedule
6.1 The replacement or overhaul of time-lifed components required in an Airworthiness Limitations Section of the aeroplane’s maintenance manual and any special techniques required by the manufacturer or an Airworthiness
Directive are required to be complied with.
CAR 1988
(f) set out details of the approved maintenance data used to
carry out the maintenance;
I wait to see what I get back from Southern region, But I think I know the answer and am happy to PM you
the results.
Last edited by Perspective; 1st Jun 2015 at 05:27.
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Yes totally in odds with what we have to do here. But that's not really to be a suprise. Because no two Casa shops will never give you the same answer. Even when you have them sitting down in front of you they will often be at odds with each other.
One large suprise here I must say is no input from cilnton or Jaba.
Fact of the matter is' if it's in your airframe maintence manual for an o/h period then you have to do it unless you have a your own SOM.
Make sure you have it I writing that's a must
One large suprise here I must say is no input from cilnton or Jaba.
Fact of the matter is' if it's in your airframe maintence manual for an o/h period then you have to do it unless you have a your own SOM.
Make sure you have it I writing that's a must
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One large suprise here I must say is no input from cilnton or Jaba.
I was at Watts Bridge for a fly in weekend.So if you really want to know, I have been far from quiet on this thread, you just had no idea. It was last Tuesday, several days before this thread started that I was contacted by SMS and phone about this very magneto matter.
My advice then was that I would not be doing it and ask my LAME to prove beyond doubt that it was required and if in doubt contact CASA for clarification.
Seems my position was backed by CASA.
Oddly enough Clinton and Brainy know each other too. And bugger me if I know where they met last
So we have been watching from the sidelines, beer in hand and loving it
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Thanks Jab, that gave me a chuckle,
An excerpt from a CASA response,
"However, CAR 42V requires persons undertaking maintenance (including inspections) to do so in accordance with applicable maintenance data. CAR 2A(2)(c) defines such data to include instructions issued by manufacturers of aircraft, components and materials."
So,
2A Approved maintenance data
(1) Subject to subregulation (3), the approved maintenance data for an aircraft, aircraft component or aircraft material consists of the requirements, specifications and instructions that are:
(a) contained in the maintenance data set out in subregulation (2); and
(b) applicable to the maintenance of the aircraft, aircraft component or aircraft material, as the case requires.
(2) For the purposes of paragraph (1)(a), the maintenance data are:
(a) requirements in:
(i) regulations 42U, 42W, 42X, 42Y, 42Z and 42ZA or in instruments made under those regulations; and
(ii) directions (however described) made under an airworthiness directive or under regulation 25, 38 or 44;
being requirements that specify how maintenance on aircraft, aircraft components or aircraft materials is to be carried out; and
(b) specifications of how maintenance on an aircraft, aircraft component or aircraft material is to be carried out, in documents or designs approved under another provision of these Regulations; and
(c) instructions, issued by the manufacturers of aircraft, aircraft components or aircraft materials, that specify how maintenance on the aircraft, components or materials is to be carried out; and
(d) instructions, issued by the designers of modifications of aircraft or aircraft components, that specify how maintenance on the aircraft or components is to be carried out; and
(e) any other instructions, approved by CASA under subregulation (4) for the purposes of this paragraph, relating to how maintenance on aircraft, aircraft components or aircraft materials is to be carried out.
These are the Regs.
Where's the ambiguity.
My surveyers are who I answer to, they direct me to this, they enforce this,
They are my first port of call if doubt exists, if you have correspondence stating otherwise I'd love to see it.
Cheers
An excerpt from a CASA response,
"However, CAR 42V requires persons undertaking maintenance (including inspections) to do so in accordance with applicable maintenance data. CAR 2A(2)(c) defines such data to include instructions issued by manufacturers of aircraft, components and materials."
So,
2A Approved maintenance data
(1) Subject to subregulation (3), the approved maintenance data for an aircraft, aircraft component or aircraft material consists of the requirements, specifications and instructions that are:
(a) contained in the maintenance data set out in subregulation (2); and
(b) applicable to the maintenance of the aircraft, aircraft component or aircraft material, as the case requires.
(2) For the purposes of paragraph (1)(a), the maintenance data are:
(a) requirements in:
(i) regulations 42U, 42W, 42X, 42Y, 42Z and 42ZA or in instruments made under those regulations; and
(ii) directions (however described) made under an airworthiness directive or under regulation 25, 38 or 44;
being requirements that specify how maintenance on aircraft, aircraft components or aircraft materials is to be carried out; and
(b) specifications of how maintenance on an aircraft, aircraft component or aircraft material is to be carried out, in documents or designs approved under another provision of these Regulations; and
(c) instructions, issued by the manufacturers of aircraft, aircraft components or aircraft materials, that specify how maintenance on the aircraft, components or materials is to be carried out; and
(d) instructions, issued by the designers of modifications of aircraft or aircraft components, that specify how maintenance on the aircraft or components is to be carried out; and
(e) any other instructions, approved by CASA under subregulation (4) for the purposes of this paragraph, relating to how maintenance on aircraft, aircraft components or aircraft materials is to be carried out.
These are the Regs.
Where's the ambiguity.
My surveyers are who I answer to, they direct me to this, they enforce this,
They are my first port of call if doubt exists, if you have correspondence stating otherwise I'd love to see it.
Cheers
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Would it not be simple to ask the C of A holder to just sign a letter instructing the LAME not to carry out sb's sl's. The C of A holder would obviously take full responsibility until such time they become mandatory!
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The only problem with that is the CofA holder probably wouldn't be around
To defend the LAME if the reason you gave him the letter in the first place
Happened!
But I'm sure his family would be understanding..
To defend the LAME if the reason you gave him the letter in the first place
Happened!
But I'm sure his family would be understanding..
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Sorry even if the CofA holder says no do do it. It is not a legal doco in regards to making the of a MR issue.
But then again what would I know in regards to issuing a MR hey Jaba.
Think you will now find that if you don't wish to do what the required maintenance that has to be done atost work shops you be politer ask that you find another workshop.
Our CofA and lic is worth more than your mags in this case.
I do find your comments Jaba to just say don't do it highly offensive as for someone that not able to actually put his hers lic on the line. But then what else would one expect from your self. Perhaps if you did or could read and understand the legislation your poor attitudei may be different. Easy to say stuff when at the end of the day you don't have any responsibility.
But then again what would I know in regards to issuing a MR hey Jaba.
Think you will now find that if you don't wish to do what the required maintenance that has to be done atost work shops you be politer ask that you find another workshop.
Our CofA and lic is worth more than your mags in this case.
I do find your comments Jaba to just say don't do it highly offensive as for someone that not able to actually put his hers lic on the line. But then what else would one expect from your self. Perhaps if you did or could read and understand the legislation your poor attitudei may be different. Easy to say stuff when at the end of the day you don't have any responsibility.
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My day job is (thankfully) much closer to that of a mechanic than a lawyer, but I suspect that 'requirement', 'direction' and 'instruction' are all carefully-chosen words that actually mean quite different things in the regs. None of it is written in a helpful way and it is a galaxy away from plain English.
Jaba wrote: "Sorry we have better things to do with our weekends."
And that's just so true...
Clinton's lovely V35 was seen parked at Dirranbandi on Saturday night and Moree on Sunday night. It was another successful drought breaking mission for the three of us. So we'll get to the pub at Tilpa, hopefully another time..
And that's just so true...
Clinton's lovely V35 was seen parked at Dirranbandi on Saturday night and Moree on Sunday night. It was another successful drought breaking mission for the three of us. So we'll get to the pub at Tilpa, hopefully another time..
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Sorry even if the CofA holder says no do do it. It is not a legal doco in regards to making the of a MR issue.
But then again what would I know in regards to issuing a MR hey Jaba.
But then again what would I know in regards to issuing a MR hey Jaba.
And just for clarity, despite what some folks here THINK they know, it should be noted what the meaning and use of approved maintenance data is and a separate issue of when to do it.
The "approved maintenance data is the "HOW" to do a job, and the maintenance schedule is the "WHEN" to do the job. Don't get them confused folks….
PS: And by the way, your last crazy and irrational post towards me where I was called a moron (which I do not object to , but clearly the mods did) was a strange attack for which you should apologise and be ashamed of. I was in fact supporting the cause of your family oddly enough. You just went off half cocked about something.
Please play the game with a straight bat hey ;-)
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Maybe not the reason why, but some relevant info for ya, that contains
Defects both mechanical and through interference.
http://www.casa.gov.au/wcmswr/_asset...awb/74/005.pdf
If that doesn't send you to sleep tnuc, interesting article also,
http://www.casa.gov.au/wcmswr/_asset...8/nov/lame.pdf
Defects both mechanical and through interference.
http://www.casa.gov.au/wcmswr/_asset...awb/74/005.pdf
If that doesn't send you to sleep tnuc, interesting article also,
http://www.casa.gov.au/wcmswr/_asset...8/nov/lame.pdf
Last edited by Perspective; 2nd Jun 2015 at 02:46.
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No, but I would hope it was after rigorous analysis of a large database of collected SDRs and reported failures, which were analysed statistically and an evidence-based figure of 4 years generated. What I suspect though was someone licked their finger, stuck it in the air and said '4 years seems 'bout right'. Wouldn't it be lovely to be proved wrong, and wouldn't the SB doc make much more interesting and useful reading if the supporting data were presented or summarised?
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The Manufacturers Data from SB643, and the relevant Overhaul manuals differs considerably.
S-1200 Series Magneto’s Manual X42001-2 (Aug 2011)
Section 2.3 – Recommended Maintenance and Overhaul periods
(D) “In addition, it is recommended that magnetos be overhauled at the expiration of four years, without regard to the accumulated operating hours since new or last overhaul.”
S-20 / S-200 Series Magneto’s Manual X42002-3 (Aug 2011)
Section 2.3 – Maintenance and Overhaul Periods
(Last Paragraph) “In addition, magnetos must be overhauled or replaced five years after the date of manufacture or last overhaul or four years after the date placed in service, which ever occurs first, without regard to accumulated operating hours since new or last overhaul.”
D-2000 / D-3000 Series Magneto’s Manual X42003-3 (Apr 2012)
Section 2.3 – Maintenance and Overhaul Periods
(Last Paragraph) “Inspect magnetos and harnesses for airworthiness at the expiration of four years, without regard to the accumulated operating hours since new or last overhaul.”
SB643B Maintenance Intervals for ALL TCM and Bendix Aircraft Magnetos and related Equipment
Sect. 4 Engine Overhaul or Four Year Interval
(D) “In addition to the requirements listed above, 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, whichever occurs first, without regard to accumulated operating hours. Also at this time all related components, including the High Tension Ignition Harness, Starting Vibrator Assembly and Ignition Switch Assembly, must be inspected for airworthiness in accordance with the procedures contained in the latest
revision of their respective Service Support Manual.”
S-1200 Series Magneto’s Manual X42001-2 (Aug 2011)
Section 2.3 – Recommended Maintenance and Overhaul periods
(D) “In addition, it is recommended that magnetos be overhauled at the expiration of four years, without regard to the accumulated operating hours since new or last overhaul.”
S-20 / S-200 Series Magneto’s Manual X42002-3 (Aug 2011)
Section 2.3 – Maintenance and Overhaul Periods
(Last Paragraph) “In addition, magnetos must be overhauled or replaced five years after the date of manufacture or last overhaul or four years after the date placed in service, which ever occurs first, without regard to accumulated operating hours since new or last overhaul.”
D-2000 / D-3000 Series Magneto’s Manual X42003-3 (Apr 2012)
Section 2.3 – Maintenance and Overhaul Periods
(Last Paragraph) “Inspect magnetos and harnesses for airworthiness at the expiration of four years, without regard to the accumulated operating hours since new or last overhaul.”
SB643B Maintenance Intervals for ALL TCM and Bendix Aircraft Magnetos and related Equipment
Sect. 4 Engine Overhaul or Four Year Interval
(D) “In addition to the requirements listed above, 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, whichever occurs first, without regard to accumulated operating hours. Also at this time all related components, including the High Tension Ignition Harness, Starting Vibrator Assembly and Ignition Switch Assembly, must be inspected for airworthiness in accordance with the procedures contained in the latest
revision of their respective Service Support Manual.”
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So where dose this end. What about fuel pumps, vac pumps etc etc. the manufacturer places this o/h limits for a reason. Weather you expect that or not that's the case. If you wish to have reliability in your aircraft and don't go on about how someone changed something and now it don't work. Point is the system has changed in regard to maintenance and you all have to except that or get your own som approved and try and convince someone to sign off on it with nil data against what the manufacturer has said. But don't blame the maintenance org for having to enforce something they don't have any option to do and weather or not we have an opinion on it. Because we relize what's good and what's not but we can't change it. And when an AWI grounds an aircraft because one decal is missing on an door well what do you won't me to say.