Maintenance Schedule
The Australian Regulations for maintenance are not that difficult to interpret,
If that is the case, given the length and breadth of enforcement actions here, by CASA, and the number off, versus the relative US situation, where formal enforcement action is rare, one must conclude that a large proportion of LAMEs in Australia either:
(a) do not have a Grade 9 standard of reading and comprehension, or;
(b) are incompetent, compared with their US counterparts, or;
(c) are crooks.
I don't believe any of the above is true, and with some very, very rare and startling exceptions that are or were (b) and/or (c) the very great majority are competent, and do their very best in a very bad system.
A system that has no international counterpart for prescriptive, complex, convoluted and contradictory regulation, that allows the universally acknowledged plague where no two FOI or AWI can agree on what the rules mean. There is simply not rational (and certainly not air safety) reason for the Australian system, vis a vie literally rest of the world.
This is what "Rule by Law" means, instead of "Rule of Law". In Australia, it is "Rule by Law", in the USA it is "Rule of law".
The structure and character of the US rules (or NZ, or Canada) simply do not make room for the employees of CASA to do what they do, do what they like.
There is nothing that stops you having a N- or ZK- aircraft in Australia, but there are a few wrinkles, such as domicile of the Certificate of Registration holder, not hard to arrange. Re. maintenance, ZK- is the easiest, thanks to the Trans Tasman Mutual Recognition Treaty, it is easy for an Australian LAME to be registered, for an IA, a short course of several days at Lower Hutt is required, but the number of NZ IAs in AU is increasing. NZ do not require any specific foreign workshop approval, with a minor caviat, the workshop must be approved by an ICAO state, if a workshop approval is required.
But, why is a workshop approval required here?? It wasn't always, the change was driven by commercial self-interest --- with a PR gloss of "improving safety". Ain't required in US, within the limits I have already outlined.
Re. McDermotts, CASA haven't "allowed" them to do anything, but the thinking that "all is prohibited unless permitted by CASA" is alive and well, clearly.
As the law stands, including operating a foreign registered aircraft on an Australian AOC (the Heavy Lift Helicopter case) CASA can't stop them. This was a case with a major constitutional element, there is no way any Australian Government is going to introduce a referendum to amend the constitution of Australia, just to give more power to CASA. And not just because a referendum would cost several hundred million $$$.
The legal precedent was firmly established by the Hawke government during the 1989 pilot dispute.
All of this should not be necessary, the whole buggers muddle of Australian regulation, with huge negative economic impact, across the board, is an utter disgrace.
It is political cowardice and opportunism, and an industry collectively without enough backbone to defend itself, and the blatant and ruthless exploitation of the "mystique of aviation safety" by the bureaucracy, that have allowed the situation.
It is far from clear that the capacity exists to do anything about it.
Few maintenance orgs. are members of AMROBA --- why not all !!
Few pilots and owners are members of AOPA --- Why not most !!
For those of you here calling for AOPA action --- are you members of AOPA??
In one of my posts, I put a link to a USA Today article, with pictures, of the huge maintenance facility QANTAS has built in US at KLAX (instead of somewhere in Australia) --- why do you think they have done that?? But there was not one single comment. It sure ain't just for PR.
Tootle pip!!
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So leadie ill ask you once more to please answer the questions i have raised with yourself and the last one which ill give again.
If an Australian AD refers to a AWB is dose this make the Awb legal document to which you must apply.
If an Australian AD refers to a AWB is dose this make the Awb legal document to which you must apply.
Conned Rod,
Without knowing which AWB you are referring to, because you didn't put up a link, I would hazard a guess it is the one about gaining a Maintenance Approval, an MA.
Show us all the alleged instrument that has been made under CAR 42 ZC(6) or any other, which purports to override Schedule 8 as it stands.
As for your last post, that has already been comprehensively answered by me and others, including direct quotes from CASA documents.
Tootle pip!!
Without knowing which AWB you are referring to, because you didn't put up a link, I would hazard a guess it is the one about gaining a Maintenance Approval, an MA.
Show us all the alleged instrument that has been made under CAR 42 ZC(6) or any other, which purports to override Schedule 8 as it stands.
As for your last post, that has already been comprehensively answered by me and others, including direct quotes from CASA documents.
Tootle pip!!
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Conned Rod,
Without knowing which AWB you are referring to, because you didn't put up a link, I would hazard a guess it is the one about gaining a Maintenance Approval, an MA.
Show us all the alleged instrument that has been made under CAR 42 ZC(6) or any other, which purports to override Schedule 8 as it stands.
As for your last post, that has already been comprehensively answered by me and others, including direct quotes from CASA documents.
Tootle pip!!
Without knowing which AWB you are referring to, because you didn't put up a link, I would hazard a guess it is the one about gaining a Maintenance Approval, an MA.
Show us all the alleged instrument that has been made under CAR 42 ZC(6) or any other, which purports to override Schedule 8 as it stands.
As for your last post, that has already been comprehensively answered by me and others, including direct quotes from CASA documents.
Tootle pip!!
I gave you the reference for the document in regrads to training
Irrespective of which awb it is as you have clearly stated an awb is not law please just answer the question i have asked of you.
The crap posted by "Connedrod" and "Bandalot" - demonstrating their voluminous knowledge of the minutiae of CASA maintenance regulation simply demonstrates the corrupt, stupid and vicious nature of the regulations and those who administer them.
I call the regulations and the regulator "stupid" using the economic definition of stupidity: doing an act that does harm to everyone involved without producing any benefit at all to anyone with the possible exception of lawyers.
Lets be clear on this; a thief or a bandit is not stupid in the economic sense because they gain while the victim loses. Stupidity is where everyone loses.
What CASA does:
- produces no measurable gain in safety for the RPT travelling public. CASA can't regulate Qantas, they dont have the capability. As for second and Third tier operators, CASA admits in their response to the NGA ditching that they cannot detect safety errors.
- saddles industry with major compliance costs for no safety benefit.
- increases commercial risk through capricious behaviour.
The above two items have a negative effect on investment, growth and job creation.
So all around, Australia loses. We lose jobs, investment, economic growth opportunities, all for no nett safety increase and at an enormous cost in tax dollars.
We are stupid for putting up with this.
To put that another way, when has the calibration of a torque wrench used to tighten a tyre valve cap saved us from a major air disaster?
I spent two years as a plant engineer for a major oil terminal and then six at Ansett. The most important safety system component - common sense, is missing completely from CASA and the regulations.
I call the regulations and the regulator "stupid" using the economic definition of stupidity: doing an act that does harm to everyone involved without producing any benefit at all to anyone with the possible exception of lawyers.
Lets be clear on this; a thief or a bandit is not stupid in the economic sense because they gain while the victim loses. Stupidity is where everyone loses.
What CASA does:
- produces no measurable gain in safety for the RPT travelling public. CASA can't regulate Qantas, they dont have the capability. As for second and Third tier operators, CASA admits in their response to the NGA ditching that they cannot detect safety errors.
- saddles industry with major compliance costs for no safety benefit.
- increases commercial risk through capricious behaviour.
The above two items have a negative effect on investment, growth and job creation.
So all around, Australia loses. We lose jobs, investment, economic growth opportunities, all for no nett safety increase and at an enormous cost in tax dollars.
We are stupid for putting up with this.
To put that another way, when has the calibration of a torque wrench used to tighten a tyre valve cap saved us from a major air disaster?
I spent two years as a plant engineer for a major oil terminal and then six at Ansett. The most important safety system component - common sense, is missing completely from CASA and the regulations.
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Leadsled, There are very few actions taken by CASA against maintainers, that I know of. Perhaps you can expand further on any vexatious actions taken by CASA, against maintainers, that I may be unaware of.
The recent cases I have knowledge about, were indeed warranted, although I perhaps would have gone about it slightly differently.
I am perplexed by your continuous reference to different interpretations by various CASA regions, having worked in all but taswegia, which I think comes under the southern office anyway. I have found them all to have similar interpretations of the maintenance regs, perhaps the FOIs are a different kettle of wombats?
If I have doubts about any maintenance issues, I have found a quick phone all to any of the three AWIs, that I maintain a professional relationship with, quickly solves the problem.
We LAMEs are still working our way through the new regulations, and appreciate the input from old hands such as yourself and Gerry, but perhaps cut the emotion a bit mate, it is making it hard to hear what you are saying.
Sunfish, What CASA does:
- produces no measurable gain in safety for the RPT travelling public. CASA can't regulate Qantas, they dont have the capability. As for second and Third tier operators, CASA admits in their response to the NGA ditching that they cannot detect safety errors.
- saddles industry with major compliance costs for no safety benefit.
- increases commercial risk through capricious behaviour.
What utter unsubstantiated bullsh1t. Go home and fix your ultralight.
To put that another way, when has the calibration of a torque wrench used to tighten a tyre valve cap saved us from a major air disaster?
There is no torque on valve caps, and if you can't see the reason for calibrating torque wrenches, as well as keeping a track of component maintenance using each torquewrench, I also call bulsh1t on your supposed history as an engineer.
The recent cases I have knowledge about, were indeed warranted, although I perhaps would have gone about it slightly differently.
I am perplexed by your continuous reference to different interpretations by various CASA regions, having worked in all but taswegia, which I think comes under the southern office anyway. I have found them all to have similar interpretations of the maintenance regs, perhaps the FOIs are a different kettle of wombats?
If I have doubts about any maintenance issues, I have found a quick phone all to any of the three AWIs, that I maintain a professional relationship with, quickly solves the problem.
We LAMEs are still working our way through the new regulations, and appreciate the input from old hands such as yourself and Gerry, but perhaps cut the emotion a bit mate, it is making it hard to hear what you are saying.
Sunfish, What CASA does:
- produces no measurable gain in safety for the RPT travelling public. CASA can't regulate Qantas, they dont have the capability. As for second and Third tier operators, CASA admits in their response to the NGA ditching that they cannot detect safety errors.
- saddles industry with major compliance costs for no safety benefit.
- increases commercial risk through capricious behaviour.
What utter unsubstantiated bullsh1t. Go home and fix your ultralight.
To put that another way, when has the calibration of a torque wrench used to tighten a tyre valve cap saved us from a major air disaster?
There is no torque on valve caps, and if you can't see the reason for calibrating torque wrenches, as well as keeping a track of component maintenance using each torquewrench, I also call bulsh1t on your supposed history as an engineer.
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Sunfish
The crap posted by "Connedrod" and "Bandalot" - demonstrating their voluminous knowledge of the minutiae of CASA maintenance regulation simply demonstrates the corrupt, stupid and vicious nature of the regulations and those who administer them.
Thats because unlike you we have too. If we dont know these regs we be in the big house and believe me you and the rest are not worth going to the big house for.
What im trying to show is that a certain person on here that trys to dictate to everyone his apparent superior knowledge is in fact so incorrect its not funny. To the point off giveing information on these pages which is clear wrong and incorrect.
If this person put the correct information on here there would be no reason to post against him.
But if you post tge wrong thing i have the right to place the correct information. Dont you think thats a far comment.
This stuff cant be taught it can only be learnt over years and the consant change to the regulations is almost impossible to understand and keep up with.
This is not the engineers fault.
And if you think this is bad then wait if you have to work with the oil and gas industries they make casa look like a pre school.
Toot toot
The crap posted by "Connedrod" and "Bandalot" - demonstrating their voluminous knowledge of the minutiae of CASA maintenance regulation simply demonstrates the corrupt, stupid and vicious nature of the regulations and those who administer them.
Thats because unlike you we have too. If we dont know these regs we be in the big house and believe me you and the rest are not worth going to the big house for.
What im trying to show is that a certain person on here that trys to dictate to everyone his apparent superior knowledge is in fact so incorrect its not funny. To the point off giveing information on these pages which is clear wrong and incorrect.
If this person put the correct information on here there would be no reason to post against him.
But if you post tge wrong thing i have the right to place the correct information. Dont you think thats a far comment.
This stuff cant be taught it can only be learnt over years and the consant change to the regulations is almost impossible to understand and keep up with.
This is not the engineers fault.
And if you think this is bad then wait if you have to work with the oil and gas industries they make casa look like a pre school.
Toot toot
you have clearly stated an awb is not law please
CASA clearly state a AWB is not law, all I do is agree with CASA. Depending on circumstances, it may well be an "acceptable means of compliance".
---- that I know of---
Many, of which I am very aware, would not appreciate my posting anything here that might otherwise identify.
Part of my point is that many CASA NCNs would never have occurred in the FAA (or NZ or Canadian) system, because NCN was based on the complex and prescriptive nature of Australian regulation, in the other jurisdictions, the matter would not arise.
Further, in those systems, in most matters that do arise, an "educational" approach is properly used, rather than raising audit reports, listing NCNs and invoking a time consuming acquittal/penalty system. The latter is reserved for what any of us would recognise as deserving of formal sanction.
A completely disproportionate level of cost, in almost every area of Australian aviation, is in dealing with "legal" completion of paperwork, with no necessary contribution to improved air safety.
All NAAs have paperwork, but in Australia it is entirely disproportionate to hours of hands on, on actual aircraft. In the US, there is national legislation, that is enforced on FAA, to limit paperwork, FAA must justify it.
What utter unsubstantiated bullsh1t. Go home and fix your ultralight.
Clearly, you have not read the Forsyth Report, or many other inquiry reports into CASA and its predecessors, over many years.
Unfortunately, the major's submissions to Forsyth were confidential, which, if nothing else, says something (and I do know what) about their reluctance to make any public criticism of CASA, after what happened to Tiger. And what do I know --- that much to the surprise of Forsyth and Co., the major's complaints were largely the same as the little end of town. But the $$$ costs are much bigger.
But, they have one great advantage, they can and have moved most of their maintenance offshore --- and for those of you who console yourselves that it is "just cheap Asian labor", explain the huge QANTAS investment in US, or why you will find QANTAS A330 in Hamburg. In the aviation business, "Cheap Asian labor" is a myth, "high productivity" is not.
Sunfish,
You have nailed it!!.
Tootle pip!!
Last edited by LeadSled; 27th Nov 2017 at 04:14. Reason: typo, para added.
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CASA clearly state a AWB is not law, all I do is agree with CASA. Depending on circumstances, it may well be an "acceptable means of compliance".
So then the following
Ad gen 65 a5 fire extinguishers
To
Awb 26-002
To
Awb 26-003
Which states continuing maintenance require on fire extinguishers.
THE FOLLOWING NOT IN THE AWB BUT LAW
And as law for any aircraft which are released for a period of over 6 months must comply in Part 1 of the M/R and added for maintenance required there after the realsed of the aircraft and before reissue of the next M/R iaw 42ze now 42h
This states the awb statements are not found anywere else in the regulations.
There fore to find out what MUST BE COMPLIED WITH YOU HAVE TO GO TO THE AWB.
All work MUST BE CARRIED OUT IAW A APPROVED DOCUMENT.
The approved document on the m/r statement is
6 month fire extinguisher reweigh iaw awb-26-006a6
This makes the awb a regulation that must be compied with.
Forgot to add that futher exams outside of casa and still goverment must now be carried out to gain certification to handle some types of fire extinguishers
So then the following
Ad gen 65 a5 fire extinguishers
To
Awb 26-002
To
Awb 26-003
Which states continuing maintenance require on fire extinguishers.
THE FOLLOWING NOT IN THE AWB BUT LAW
And as law for any aircraft which are released for a period of over 6 months must comply in Part 1 of the M/R and added for maintenance required there after the realsed of the aircraft and before reissue of the next M/R iaw 42ze now 42h
This states the awb statements are not found anywere else in the regulations.
There fore to find out what MUST BE COMPLIED WITH YOU HAVE TO GO TO THE AWB.
All work MUST BE CARRIED OUT IAW A APPROVED DOCUMENT.
The approved document on the m/r statement is
6 month fire extinguisher reweigh iaw awb-26-006a6
This makes the awb a regulation that must be compied with.
Forgot to add that futher exams outside of casa and still goverment must now be carried out to gain certification to handle some types of fire extinguishers
makes the awb a regulation that must be compied with.
Rubbish, it does not change the legal status of the AWB, its status is as defined by CASA.
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Leadsled,
Many, of which I am very aware, would not appreciate my posting anything here that might otherwise identify.
Part of my point is that many CASA NCNs would never have occurred in the FAA (or NZ or Canadian) system, because NCN was based on the complex and prescriptive nature of Australian regulation, in the other jurisdictions, the matter would not arise.
Yes indeed, but I was in fact looking at cases where maintainers or AMOs had been taken to court by CASA over breaches.
I am well aware of the generation of multiple NCNs for a single breach, in fact had to deal with the drunkard from Darwine for several of my clients.
The most difficult part is answering the NCN - Root cause, corrective action and preventative action. Have had several responses to NCNs returned, as they didn't like my answer of root cause being CASA's interpretation of the regulation.
There is (maybe are?) two types of CASA maintenance data: Approved Data and then Acceptable Means of Compliance. In the case of AWBs, I view these as Acceptable Means of Compliance, which is probably along the lines of ConnedRod viewing them as LAW, the same as Approved data.
Many, of which I am very aware, would not appreciate my posting anything here that might otherwise identify.
Part of my point is that many CASA NCNs would never have occurred in the FAA (or NZ or Canadian) system, because NCN was based on the complex and prescriptive nature of Australian regulation, in the other jurisdictions, the matter would not arise.
Yes indeed, but I was in fact looking at cases where maintainers or AMOs had been taken to court by CASA over breaches.
I am well aware of the generation of multiple NCNs for a single breach, in fact had to deal with the drunkard from Darwine for several of my clients.
The most difficult part is answering the NCN - Root cause, corrective action and preventative action. Have had several responses to NCNs returned, as they didn't like my answer of root cause being CASA's interpretation of the regulation.
There is (maybe are?) two types of CASA maintenance data: Approved Data and then Acceptable Means of Compliance. In the case of AWBs, I view these as Acceptable Means of Compliance, which is probably along the lines of ConnedRod viewing them as LAW, the same as Approved data.
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Please explain what a civil court would view a awb if something went wrong and ypu hadn't done it iaw.
As a lame i have the legal right to veiw and use the regulations. It dose not give me a legal right as an lame to fly a 747.
I am toally amazed at you lack of knowledge on this subject, ypu have absolutely zero detail knowledge on this subject containing maintenance. This has been proven how many times now just in these two threads.
So without being an onwer operator what legal right do you have to use these regulations for certification in regrads for aircraft maintenance.
Im sure you will not answer that question as you refuse to answer any questions i have ask of you.
ConnedRod, Yr Right, Band, Bend or whatever pseudonym you are going under today, I am sure you are a good LAME and I am sure you can comply with CASA and keep the NCN's to a minimum. I am sure CASA has a bit of respect for you. In short I am sure you know heaps .... look, I would even let you work on my aeroplane if you promised to stay away from your phone.
But a lawyer you aint!
But a lawyer you aint!
Now you are talking civil court, not breaching CASA regs?
I would have my lawyer quote from the CASA webpage about AWB's which says;
"The information in the bulletins isn't mandatory."
When something isn't mandatory it means you are not obliged to do it.
I look at each AWB on it's merits. If there is no safety gain, I note the information and get on with life without spending unnecessary money.
Never claimed to be a Lawyer.
A AWB that contains maintenance data is "approved data" (Ref REG 2a it comes from CAsA).
If A AD says to referw to a AWB then you do but your certification for work will say AD/XXX/X carried out (not AWB carried out).
You will also not that as per the pervious post that I did The AD needs to be the document used as it is both a higher order and a later publication relating to the same instruction (you cant write an AD reference number if that publication does not yet exist).
A AWB that contains maintenance data is "approved data" (Ref REG 2a it comes from CAsA).
If A AD says to referw to a AWB then you do but your certification for work will say AD/XXX/X carried out (not AWB carried out).
You will also not that as per the pervious post that I did The AD needs to be the document used as it is both a higher order and a later publication relating to the same instruction (you cant write an AD reference number if that publication does not yet exist).
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ConnedRod, Yr Right, Band, Bend or whatever pseudonym you are going under today, I am sure you are a good LAME and I am sure you can comply with CASA and keep the NCN's to a minimum. I am sure CASA has a bit of respect for you. In short I am sure you know heaps .... look, I would even let you work on my aeroplane if you promised to stay away from your phone.
But a lawyer you aint!
But a lawyer you aint!
So how about less negative and listen to what is being said. I have no problem if poeple dont know. Ill always take the time and explain what why how. But what i dont like is being told im wrong by someone that clearly is themselves or being told how do i know little bits of regs that you may not know off. Its easy because its my job. If you ever notice there is a lot off stuff on this site i dont make comment on .
But when i do make commet well thats another story.
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Now you are talking civil court, not breaching CASA regs?
I would have my lawyer quote from the CASA webpage about AWB's which says;
"The information in the bulletins isn't mandatory."
When something isn't mandatory it means you are not obliged to do it.
I look at each AWB on it's merits. If there is no safety gain, I note the information and get on with life without spending unnecessary money.
I would have my lawyer quote from the CASA webpage about AWB's which says;
"The information in the bulletins isn't mandatory."
When something isn't mandatory it means you are not obliged to do it.
I look at each AWB on it's merits. If there is no safety gain, I note the information and get on with life without spending unnecessary money.
Please explain how you would release say ad gen 65 for a start, then say an oncondtion engine ?
Why civil court
Because we work under two sets of rules in this time of litigation. Whist you may preform every thing in casa eyes correctly if for an accident say on condition engine fail how do ypu explain ypur sleve in a civil court when you are ask how come you released tnis engine.
If you say iaw tbe ad and awb tnats fine, but sir you have gone diecertly agaist the the Manufacturer recommendations. How do you get out of that. Oh yeh the engine failed and multiple deaths
Please answer tgbat for me ta in advance.
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Never claimed to be a Lawyer.
A AWB that contains maintenance data is "approved data" (Ref REG 2a it comes from CAsA).
If A AD says to referw to a AWB then you do but your certification for work will say AD/XXX/X carried out (not AWB carried out).
You will also not that as per the pervious post that I did The AD needs to be the document used as it is both a higher order and a later publication relating to the same instruction (you cant write an AD reference number if that publication does not yet exist).
A AWB that contains maintenance data is "approved data" (Ref REG 2a it comes from CAsA).
If A AD says to referw to a AWB then you do but your certification for work will say AD/XXX/X carried out (not AWB carried out).
You will also not that as per the pervious post that I did The AD needs to be the document used as it is both a higher order and a later publication relating to the same instruction (you cant write an AD reference number if that publication does not yet exist).
Yes the higher reg is listed but when in a fire extinguisher ad gen 65 its very basic. The awb states the info and as such it is what th e maintenance is required and so that becomes tne inspection that is placed on the m/r