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Old 22nd Nov 2017, 20:14
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Sorry should be We are all Negan. Stolen from The Walking Dead Season 8.
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Old 23rd Nov 2017, 07:38
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There are many places and it is in the regs - but you can not do less than the manufacturer states.

http://abs.org.au/uploads/CASA_AWB_0..._June_2006.pdf

Also google "maintenance guide for owner/operators

NOTE - this has been taken to court twice and both times the same result - you need to do what the manufacture says or more, not less.
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Old 23rd Nov 2017, 07:48
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Originally Posted by haydnc
Would you be able to provide me with a regulation for this?

You've suddenly put out of the air every aircraft that has not had a prop (AD Prop 1) and governors overhaul every 6 years, Every aircraft that hasn't had new hoses fitted every 5 years, every aircraft that has an engine past 12 years since overhaul, actually most aircraft maintained on schedule 5.

I think you may be confusing items listed as airworthiness limitations which are applicable to the type certificate, not maintenance schedules listed in the maintenance manual.

Haydn


See previous post above.

Engine hoses and CSU are exempt via AD/ENG/4 from memory for private.


Prop is exempt via AD/PROP/1 I think (but new calendar times were/are being introduced.

Anything not covered by an AD from CAsA, must be no less than what the manufacturer states or it is a strict liability of 50 points from memory.
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Old 23rd Nov 2017, 09:24
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Anything not covered by an AD from CAsA, must be no less than what the manufacturer states or it is a strict liability of 50 points from memory.
I was not aware strict liability applied to advisory material.

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Old 23rd Nov 2017, 09:37
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Originally Posted by haydnc
I was not aware strict liability applied to advisory material.



Read again it is in the regs too - but you research it mate.

As said it has been to court.

My memory says it was 50 penalty units - you prove me wrong.
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Old 23rd Nov 2017, 12:51
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I was not aware strict liability applied to advisory material.
Haydnc,
What "advisory" , as in AC, means in this context is "a way but not the only way" of complying with a regulatory requirement.

You can do "it", what ever "it" is per the AC, or you can negotiate an alternative means of compliance with CASA to perform "it".

Either way, you must comply, on pain of whatever the penalty is for non-compliance with the regulation. This simple concept, common in aviation throughout the western world, seems to be very difficult for a significant percentage of participants in Australian aviation to grasp.

That is why we have the crass stupidity of Manuals of Standards and any amendments subject to virtually full on Parliamentary processes, at huge cost and inflexibility.

The fatuous Australian bush lawyer claim that "Advisory" means that you can decide not to comply, in one form or another, because it doesn't have that Australian aviation favorite "command" word, "Mandatory" will not wash.

Just like the interminable debate about "should" and "shall", do you think that "The C.of R holder should complete maintenance in accordance with manufacturer's Instructions" and "the C.of R. holder shall complete -----" have different meanings?

Tootle pip!!

Last edited by LeadSled; 24th Nov 2017 at 07:01. Reason: typo corrected
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Old 23rd Nov 2017, 18:35
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An ac is only law if there is not a higher reg that covers it. Once again alot of tnis comes back to aopa and getting back to manufacturers som etc. This has lead to removed ads and being placed in 100.5. At the end of the day the ower/operator is repossibe for maintenance that is carried out on there aircraft.
Toot toot
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Old 24th Nov 2017, 07:24
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An ac is only law if there is not a higher reg that covers it.
Conned rod,
An AC is never L-A-W black letter law, in almost all cases it is exactly as I said, an acceptable means of compliance with a statutory requirement.
In any other case, it is just good advice, and should be heeded, if you are half-way smart.

I think I have got the AOPA bit now:
In the 1990s, AOPA campaigned to get rid of all of Australia's unique airworthiness standards, in favor of the US version of ICAO standards, we did not accept that Australian air was different to the rest of the world. We didn't believe in bureaucratic make-work programs funded by the aviation industry.

We did not accept that Australian aircraft owners should be saddled with often quite massive costs to put an aircraft on the Australian register, and this was not GA, but airlines, as well. Especially airlines, where the additional costs were in the tens of millions, not just tens of thousands.

We never found any of the AD/Gens under discussion with any justification: That is, the alleged risk to be mitigated was simply imagination, or otherwise not within a bull's roar of justifying the cost of mitigation, ie: miserably failed any benefit/ cost study.

The Howard Opposition took that to the 1996 elections, and policy implementation began in mid-1998. That was and is CASR Parts 21-35.

I can well imagine that you would not be happy, it cost you "money for nothing", but the greater good of ridding Australia of completely unjustified and and hugely costly unique airworthiness standards was the aim, and that was achieved, over huge opposition from within CASA ---- and a few people, presumably like you.

The changes, for just one example, transformed the available payload on a B767-238/338 on medium length runways. It eliminated "first of type" certification costs for all aircraft. There was lots more.

Sadly, far to many of what we got rid of are back, reintroduced by stealth as "additional airworthiness requirement", Australia is the loser, again both GA and airlines.

In the airline case, to the benefit of international competition, and to the cost of large number of jobs in Australia. Why is Padstow TAFE Aeroskils course finito, or almost so??

https://www.usatoday.com/story/trave...ngar/97235004/

Why do you think Qantas has gone to this trouble??

Tootle pip!!

Last edited by LeadSled; 24th Nov 2017 at 07:36.
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Old 24th Nov 2017, 08:39
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It is a bit scary when you tell people and show advisory material from the people that have made many an aviator broke and a non aviators, the position of CAsA.

Then they still believe a line in a CAsA document means that they don't need to do the minimum maintenance that the manufacture states.

And CAsA will let them fly as many hours as they wish ( 8 hrs a day 365 days a year) 2,920 a year all on the 1 MR issue with no other maintenance due!

Now that will be very thick oil by the end of year.


I think I know exactly where the insurance companies will side and how the 1988 REGs are interpreted - But some people like a very dark grey!
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Old 24th Nov 2017, 09:44
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Originally Posted by LeadSled
Conned rod,
An AC is never L-A-W black letter law, in almost all cases it is exactly as I said, an acceptable means of compliance with a statutory requirement.
In any other case, it is just good advice, and should be heeded, if you are half-way smart.

I think I have got the AOPA bit now:
In the 1990s, AOPA campaigned to get rid of all of Australia's unique airworthiness standards, in favor of the US version of ICAO standards, we did not accept that Australian air was different to the rest of the world. We didn't believe in bureaucratic make-work programs funded by the aviation industry.

We did not accept that Australian aircraft owners should be saddled with often quite massive costs to put an aircraft on the Australian register, and this was not GA, but airlines, as well. Especially airlines, where the additional costs were in the tens of millions, not just tens of thousands.

We never found any of the AD/Gens under discussion with any justification: That is, the alleged risk to be mitigated was simply imagination, or otherwise not within a bull's roar of justifying the cost of mitigation, ie: miserably failed any benefit/ cost study.

The Howard Opposition took that to the 1996 elections, and policy implementation began in mid-1998. That was and is CASR Parts 21-35.

I can well imagine that you would not be happy, it cost you "money for nothing", but the greater good of ridding Australia of completely unjustified and and hugely costly unique airworthiness standards was the aim, and that was achieved, over huge opposition from within CASA ---- and a few people, presumably like you.

The changes, for just one example, transformed the available payload on a B767-238/338 on medium length runways. It eliminated "first of type" certification costs for all aircraft. There was lots more.

Sadly, far to many of what we got rid of are back, reintroduced by stealth as "additional airworthiness requirement", Australia is the loser, again both GA and airlines.

In the airline case, to the benefit of international competition, and to the cost of large number of jobs in Australia. Why is Padstow TAFE Aeroskils course finito, or almost so??

https://www.usatoday.com/story/trave...ngar/97235004/

Why do you think Qantas has gone to this trouble??

Tootle pip!!
Once again your total lack of knowledge is self evidence of not knowing what you are talking about. An ac awb is considered law if there is not a higher document ie ad car etc. Please do some home work before you manage to place ypur litt,e fingers onto the key board.
AD Gens are still required in a CofA and requirements of a service.
Qantas is thhe main player in the degradation of the licence system we currently have. A lic which tells you more of what you cant do than what you can . Why arnt there any engineering niw is because you can make more money making ice creams and considerable more . So until you clowns wake up that your maintenance is to cheap for what you are getting the decline will continue.
And shen you read what is written on this site why would you wish to do all that training sudy. Oh wait its not uni so we cant call oursleves engineers.
Toot toot
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Old 24th Nov 2017, 10:23
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The CASA webpage on AWBs does not say it is law. What it does say is this:
"We issue airworthiness bulletins (AWB) to give you important information. The information in the bulletins isn't mandatory."

Is that plain enough?

https://www.casa.gov.au/aircraft/standard-page/airworthiness-bulletins-0
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Old 24th Nov 2017, 10:37
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It is not law as you say it - but that is info from the law maker - on the interpretation of the REGs from the Legal Team.

So it is not a passing comment either and one with precedent.


But correct a AWB is lot a LAW.
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Old 24th Nov 2017, 11:33
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Originally Posted by Connedrod
Once again your total lack of knowledge is self evidence of not knowing what you are talking about. An ac awb is considered law if there is not a higher document ie ad car etc. Please do some home work before you manage to place ypur litt,e fingers onto the key board.
AD Gens are still required in a CofA and requirements of a service.
Qantas is thhe main player in the degradation of the licence system we currently have. A lic which tells you more of what you cant do than what you can . Why arnt there any engineering niw is because you can make more money making ice creams and considerable more . So until you clowns wake up that your maintenance is to cheap for what you are getting the decline will continue.
And shen you read what is written on this site why would you wish to do all that training sudy. Oh wait its not uni so we cant call oursleves engineers.
Toot toot
Classic 'yr right' stuff.
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Old 24th Nov 2017, 12:04
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An ac awb is considered law
Conned Rod,
Do you really have a serious problem with the English language, or are you just having us all on??

I hope it either the latter, or you are not really a LAME at all.

I would have thought that the topics covered in an Airworthiness Administration examination (or whatever it is currently called) adequately covered the hierarchy of Australian primary and secondary legislation and supporting documents, in the aviation case being the Act, Regulations, & Manuals of Standards, subject to the Cth. Legislative Instruments Act 2003, Airworthiness Directives, and supporting material CAAPs for CARs, ACs for CASRs, and the various AWBs.

Because, based on the "knowledge" of airworthiness matters exhibited in many of your recent posts, it is my opinion that I would not have you anywhere near any aircraft, for which I had any responsibility.

An AC is an Advisory Circular, it is NOT "the law". What an AC is, has been dealt with.

An Airworthiness Bulletin, AWB, is a completely different document, but again, as a previous poster has made clear, it is not law.

That more than one AWI of my acquaintance thinks as you do, that an AWB has the force of law, does not make it so, just because he or she has a CASA ID. That is just another example of "rule by law".

There is no such thing as an AC AWB, that I have seen of heard of, prove otherwise by providing a link to an example, not by a repeated assertion.

Tootle Pip!!
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Old 24th Nov 2017, 18:31
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Originally Posted by LeadSled
Conned Rod,
Do you really have a serious problem with the English language, or are you just having us all on??

I hope it either the latter, or you are not really a LAME at all.

I would have thought that the topics covered in an Airworthiness Administration examination (or whatever it is currently called) adequately covered the hierarchy of Australian primary and secondary legislation and supporting documents, in the aviation case being the Act, Regulations, & Manuals of Standards, subject to the Cth. Legislative Instruments Act 2003, Airworthiness Directives, and supporting material CAAPs for CARs, ACs for CASRs, and the various AWBs.

Because, based on the "knowledge" of airworthiness matters exhibited in many of your recent posts, it is my opinion that I would not have you anywhere near any aircraft, for which I had any responsibility.

An AC is an Advisory Circular, it is NOT "the law". What an AC is, has been dealt with.

An Airworthiness Bulletin, AWB, is a completely different document, but again, as a previous poster has made clear, it is not law.

That more than one AWI of my acquaintance thinks as you do, that an AWB has the force of law, does not make it so, just because he or she has a CASA ID. That is just another example of "rule by law".

There is no such thing as an AC AWB, that I have seen of heard of, prove otherwise by providing a link to an example, not by a repeated assertion.

Tootle Pip!!

Once again you know it it all.

So as please answer these in a yes or no.

Have you signed in the cerification in the lame column for aircraft maintenance for a service.
Yes / no

Have you singed a category certification after maintenance.
Yes / no

Have you signed and issue a M/R for an aircraft after maintenance.
Yes / no

Have you held a lame lic in Australia
Yes / no

Are you legal to do any maintenance out side shed 8 and out side the scope of a 2nd inspection of flight controls
Yes / no



Please answer the above questions.

I am sorry but tbe choice of working repairing your aircraft dose not belong to yourself. That choice belongs to myself.

As for ac and awb. A classic is interior fire ext. There is no reg for that so the awb becomes the approved document.
Next is releasing a engine that is on condition. Once again the manufacture gives time limits, casa gives an out via the awb which states what to do. Once agin they dont match each other. So a chatch 22 if it goes pear shape. Casa will not support you. Manufacturers will not support you as you gone against there recommendations. Your not cover under you c of a. When you release an engine you release that engine under your lic privileges on your own back. This is why lames will not release an engine now on condition.

So which is is approved data
M/m
Ipc
Msb
Sb
Si
Car
Awb
Ads


As an ex bus driver as you were. Not only are you small in statue but your small in mind. As been said to me your not allowed to have any opposing arguments even if you are correct.
This is even though i do this on a daily basis and have to work within the regs in a much tighter enivorment than sitting on the side lines shouting orders. You cant be wrong. Even when your found to be then you go onto personal attacks. This is tipical of type (bus driver) and more so because of the red tail effect double wammie.
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Old 24th Nov 2017, 21:36
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After several years of doing contact work, as in just give me the work pack and you take responsibility for the correctness of it all, I'll be moving into a position of responsibility in the new year. I have found this discussion on the "legalness" of the various CASA documents most perplexing.
For instance: AWB for fire extinguishers, is this mandatory and if so why isn't it in CAO 105.5?
Why can't I do a rotor track and balance on my licence but can do it under a CofA ?

Now onto oncondition engines: Recent experience with an IO540 C engine, satisfies Lycoming SB requirements for hard time of 2400 hours, extended from 2000 hours nominal.
Last inspection all cylinder compressions greater than 73/80 psid, boroscope inspection shows good barrels with very minor ring ridge, nil debris in oil filter for the last 1000 hours I've been looking at it.
Engine meets power requirements for flight and aircraft is released to service in aerial work category. Engine is now at 2550 hours since OH.
I had no problems releasing it for 100 hours, what are your thoughts?

Last edited by Eddie Dean; 24th Nov 2017 at 21:50.
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Old 24th Nov 2017, 23:48
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Originally Posted by Eddie Dean
After several years of doing contact work, as in just give me the work pack and you take responsibility for the correctness of it all, I'll be moving into a position of responsibility in the new year. I have found this discussion on the "legalness" of the various CASA documents most perplexing.
For instance: AWB for fire extinguishers, is this mandatory and if so why isn't it in CAO 105.5?
Why can't I do a rotor track and balance on my licence but can do it under a CofA ?

Now onto oncondition engines: Recent experience with an IO540 C engine, satisfies Lycoming SB requirements for hard time of 2400 hours, extended from 2000 hours nominal.
Last inspection all cylinder compressions greater than 73/80 psid, boroscope inspection shows good barrels with very minor ring ridge, nil debris in oil filter for the last 1000 hours I've been looking at it.
Engine meets power requirements for flight and aircraft is released to service in aerial work category. Engine is now at 2550 hours since OH.
I had no problems releasing it for 100 hours, what are your thoughts?

Do ypu mean 100.5 ? Because that is only half that is required.
As for your engine. Thats not on condition but extension under the sb. I suspect its a lyco.?
Under the sb if you meet the requirements of the sb, like min hours per month etc you can extend the o/h period.

On conditionfor the others is over a 12 year or over hours in private / aireail work . There is no on condition for charter.

If your work pack is from a approved maintenance controler then you are cover if any thing is left out of the work pack. A maintenance controller can issue for both class A and B work inspections
. A maintenance controller must be used in class A only.
Toot toot
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Old 24th Nov 2017, 23:59
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Originally Posted by Connedrod
Do ypu mean 100.5 ? Because that is only half that is required.
As for your engine. Thats not on condition but extension under the sb. I suspect its a lyco.?
Under the sb if you meet the requirements of the sb, like min hours per month etc you can extend the o/h period.

On conditionfor the others is over a 12 year or over hours in private / aireail work . There is no on condition for charter.

If your work pack is from a approved maintenance controler then you are cover if any thing is left out of the work pack. A maintenance controller can issue for both class A and B work inspections
. A maintenance controller must be used in class A only.
Toot toot
The Lycoming SB allows an extension of hard time from 2000 to 2400 hours as long as the stipulated criteria is met, it was extended past the Lycoming SB time about a month ago, and is now at about 2550, engine change to be carried out in January. So is indeed on condition in aerial work category.
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Old 25th Nov 2017, 00:04
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As a lame and if you know the aircraft and its history a better assment can be made. If its a strange aircraft you have no idea about then thats a different matter again. Basically lyco bottem ends are good. Top end exhaust valves leakage can be a problem. And the cam but if its meeting the sb the cam should be ok .
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Old 25th Nov 2017, 03:50
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Have you signed in the cerification in the lame column for aircraft maintenance for a service.
Yes / no
Have you singed a category certification after maintenance.
Yes / no
Have you signed and issue a M/R for an aircraft after maintenance.
Yes / no
Have you held a lame lic in Australia
Yes / no
Are you legal to do any maintenance out side shed 8 and out side the scope of a 2nd inspection of flight controls
Yes / no
Conner Rod,
The answer to all of the above is that the answers are irrelevant to the discussion in hand --- if, as we are expected to believe, you are a LAME, I have a couple of questions for you:

A lawyer, whether employed by CASA or other wise, is not qualified to write an opinion on aviation law if it relates to maintenance, unless they are a LAME.
Yes/No

No other person is qualified to speak on aviation law if it relates to maintenance unless they are a LAME.
Yes/No.

In short, your argument above is specious and invalid. Ask a lawyer what "jus publicum privatorum pactis mutari non potest" means.

The aviation law is what it is, not what you think it is, or what you or anybody else would like it to be.

Tootle pip!!

PS 1: As it happens, the answer to two ( and probably three) of your questions may surprise you, it is YES --- as, along with many other non-LAMEs, I have had specific maintenance approvals to do what would have otherwise required a LAME or approved person with appropriate qualifications.

PS 2: Does a Maintenance Controller have to be a LAME?

PS 3: There is no contradiction in an AWB containing an acceptable means of compliance, any more than a CAAP or AC, but you still have the flexibility of having an alternative means of compliance negotiated with CASA. But none of the three is L-A-W. This very simple concept seems to be a mystery to you. And yes, I do know the legal status of an S/B or so called MSB, including the latest FAA legal determinations of their status, which has had a significant impact on Cessna's approach to such matters, do you??

Last edited by LeadSled; 25th Nov 2017 at 04:10. Reason: PS2/3 added
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