Dipsticks
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Join Date: Dec 2002
Location: Moruya NSW Australia
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Dipsticks
We opperate 4 cessnas as training aircraft each with its own hand made wooden dipstick. CASA see's this as a problem Each dipstick is calibrated for each individual aircraft.
Excerpt from a letter from CASA FOI
Re the fuel dipstick for VH-XXX. If this item is used to release the aircraft into service, it is a tool and a piece of aircraft equipment. It is also an instrument for measuring fuel and therefore CAO 108.56 (3.4) applies. How is this item calibrated? Who calibrated it and when? What is its purpose? Where is the operations Manuel procedure for its use? What identifies the item, Is it to be used in this aircraft only or may it be used in other aircraft in your fleet?
As you can see this is a complex issue. The item in use in the aircraft would appear not to comply with the requirements the CAO, and I would suggest that in the event of an accident attributable to its use you would be vulnerable. The National Association of testing Authorities (NATA) is the body, which controls such calibration. My advice to you is to investigate the ramifications of the use of this instrument, and take action to ensure that its use is legal. If this is outside the capabilities of the club or its engineering support, then a note to the effect that the dipstick is not to be used for flight planning purposes or weight and balance calculations, should be placed in the operations manual. This will require you to set up a system, which will ensure that pilots can work out the amount of fuel in the tanks without error
Excerpt from a letter from CASA FOI
Re the fuel dipstick for VH-XXX. If this item is used to release the aircraft into service, it is a tool and a piece of aircraft equipment. It is also an instrument for measuring fuel and therefore CAO 108.56 (3.4) applies. How is this item calibrated? Who calibrated it and when? What is its purpose? Where is the operations Manuel procedure for its use? What identifies the item, Is it to be used in this aircraft only or may it be used in other aircraft in your fleet?
As you can see this is a complex issue. The item in use in the aircraft would appear not to comply with the requirements the CAO, and I would suggest that in the event of an accident attributable to its use you would be vulnerable. The National Association of testing Authorities (NATA) is the body, which controls such calibration. My advice to you is to investigate the ramifications of the use of this instrument, and take action to ensure that its use is legal. If this is outside the capabilities of the club or its engineering support, then a note to the effect that the dipstick is not to be used for flight planning purposes or weight and balance calculations, should be placed in the operations manual. This will require you to set up a system, which will ensure that pilots can work out the amount of fuel in the tanks without error
Join Date: Mar 2001
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Oh the words of wisdom from CASA! They cease to amaze me with their actions when they cant find anything else wrong with your company.
Each FOI had his own little things he likes to see. If this was such a pressing issue why is it that all operators have not been issued with such a requirement regarding the use of dipsticks? I bet you that every other GA company would struggle to find all these requirenments met in their ops manual!
Each FOI had his own little things he likes to see. If this was such a pressing issue why is it that all operators have not been issued with such a requirement regarding the use of dipsticks? I bet you that every other GA company would struggle to find all these requirenments met in their ops manual!
Join Date: Mar 2001
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CFI, some aircraft have within the maintenance manual details for making a dipstick, ie the markings as per the fitted fuel tanks, perhaps this is what you may need to find then its less likely to be a problem.
Join Date: Oct 1999
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Innovation
I am off to the shed to start making dipsticks from spare dowling, sticky back plastic and glue and then I'll do a manual in Publisher and sell them via the net for say $200 each - think CASA will approve?
Moderate, Modest & Mild.
Is the key to this letter not in the opening sentence, "If this item is used to release the aircraft into service"?
IF the answer were, "No, it is not to release it into service, but merely as a secondary check that we may, or may not, use at our discretion.", wouldn't that then pull the "lynch pin" out of the argument.
Perhaps they will then ask you if the calculator you use is an aviation approved one!!
As a further matter of interest, I wonder how they would have viewed an inscribed aluminium dipstick?
IF the answer were, "No, it is not to release it into service, but merely as a secondary check that we may, or may not, use at our discretion.", wouldn't that then pull the "lynch pin" out of the argument.
Perhaps they will then ask you if the calculator you use is an aviation approved one!!
As a further matter of interest, I wonder how they would have viewed an inscribed aluminium dipstick?
Join Date: Dec 2001
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If your approved LAME has properly calibrated each dipstick for each aeroplane, it shouldn't be too hard to tell CASA how it was done. You may have to dress it up a bit by carving the aircraft rego on each dipstick and recording somewhere the date of calibration. Their letter is just covering their legal arses and attempting to justify their existence. It has been my experience that sometimes you just tell them what it is you are doing and get on with it, because their legal ability to actually stop you from doing it may be weaker than you think.
Seems to me, you are acting responsibly with your obvious policy of dipping tanks before releasing aircraft to service. CASA would be stupid to challenge that, given that alternative methods of reading fuel quantity on the average bugsmasha are notoriously inaccurate, and shock, horor, if you always go to full tanks you may end up overloaded.
Seems to me, you are acting responsibly with your obvious policy of dipping tanks before releasing aircraft to service. CASA would be stupid to challenge that, given that alternative methods of reading fuel quantity on the average bugsmasha are notoriously inaccurate, and shock, horor, if you always go to full tanks you may end up overloaded.
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RE Dipsicks (Fuel tank type not CASA staffers)
Unfortunately anything that is used to 'measure' anything must be calibrated (naturally by an 'approved' person and organisation) they will probably also be a time requirement as well (every 12, 24, 36 months or whatever
Lets not mention the 44's (OK 200litre) drums workshops use to 'calibrate' your fuel guages every 3 years (class B private ops) or even the tyre pressure guages. The will no doubt be discovered at some stage soon.
or
The airworthiness wallah that demanded a "REMOVE BEFORE FLIGHT" placard on the INSIDE of the canopy cover for my Airtourer. I kid you NOT.
Disco Stu
PS For those too young to know the Airtourer, it would be impossible to get into one with a canopy cover in place let alone fly the jolly thing
Unfortunately anything that is used to 'measure' anything must be calibrated (naturally by an 'approved' person and organisation) they will probably also be a time requirement as well (every 12, 24, 36 months or whatever
Lets not mention the 44's (OK 200litre) drums workshops use to 'calibrate' your fuel guages every 3 years (class B private ops) or even the tyre pressure guages. The will no doubt be discovered at some stage soon.
or
The airworthiness wallah that demanded a "REMOVE BEFORE FLIGHT" placard on the INSIDE of the canopy cover for my Airtourer. I kid you NOT.
Disco Stu
PS For those too young to know the Airtourer, it would be impossible to get into one with a canopy cover in place let alone fly the jolly thing
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Feather #3
Yup, same thing. The canopy cover story even got a laugh in the Belgrano
cfiknow
The way things are headed if it isn't written in an approved document somewhere then you can't do it. For example do not use the familiar memory checklists if they are not in the Flight Manual. Have a memory lapse and forget something and you'll be hung for not using an approved document/procedure. Believe me this is the way FOI's are taught to audit
I'm not familiar with the Cessna Flight Manuals for your aircraft that you received the letter for, but I would be interested to know what they say about fuel management, especially ascertaining the quantity in tanks prior to departure. If you can show justification (authority) to use dipsticks made IAW a Cessna procedure then this needs to pursued.
Don't give up, CASA have abrigated any airworthiness and operational knowledge decisions to Cessna and the FAA, you'll get more sense out of those 2 any day.
Disco Stu
Yup, same thing. The canopy cover story even got a laugh in the Belgrano
cfiknow
The way things are headed if it isn't written in an approved document somewhere then you can't do it. For example do not use the familiar memory checklists if they are not in the Flight Manual. Have a memory lapse and forget something and you'll be hung for not using an approved document/procedure. Believe me this is the way FOI's are taught to audit
I'm not familiar with the Cessna Flight Manuals for your aircraft that you received the letter for, but I would be interested to know what they say about fuel management, especially ascertaining the quantity in tanks prior to departure. If you can show justification (authority) to use dipsticks made IAW a Cessna procedure then this needs to pursued.
Don't give up, CASA have abrigated any airworthiness and operational knowledge decisions to Cessna and the FAA, you'll get more sense out of those 2 any day.
Disco Stu
And now that you bring Airtourers into the story....
What a stroke of engineering genius that dipstick is!!!
Noticed on the Gippsland based mob that wanted to restart manufacture of Airtourers, that they had at least put the tanks in the wings. Shame they fell over.
What a stroke of engineering genius that dipstick is!!!
Noticed on the Gippsland based mob that wanted to restart manufacture of Airtourers, that they had at least put the tanks in the wings. Shame they fell over.
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At first, I couldn't figure out why C210/C206 weren't supplied new with step ladders, given that the 'average' person, especially in the 1970's is not tall enough to reach the fuel cap without making use of something to reach it.
520.
520.
A beautiful example of the communication gap between the bureaucrat and the commercial operator.
Reading the original letter with my ex-bureacrat's hat on, I'd interpret it as a genuine attempt to let you know there was a potential legal problem that you needed to address before it bit you on the bum. Basically a friendly 'heads up'.
As Kaptin M has pointed out, the solution may well be quite simple and understanding it it makes you safer in the legal minefield.
Remember, the FOI's not in a position to comment on the idiocy or otherwise of the regulation. Others have brought it into being and he's duty bound to apply it.
In the dim, dark, distant past he may well have caught up with you over a quiet Friday afternoon beer and told you there was a blooody silly rule you needed to watch out for.
In these litigious days, its got to be in bureaucrateze, at arms length, ensuring no possibility of collusion etc etc.
Just a thought
Reading the original letter with my ex-bureacrat's hat on, I'd interpret it as a genuine attempt to let you know there was a potential legal problem that you needed to address before it bit you on the bum. Basically a friendly 'heads up'.
As Kaptin M has pointed out, the solution may well be quite simple and understanding it it makes you safer in the legal minefield.
Remember, the FOI's not in a position to comment on the idiocy or otherwise of the regulation. Others have brought it into being and he's duty bound to apply it.
In the dim, dark, distant past he may well have caught up with you over a quiet Friday afternoon beer and told you there was a blooody silly rule you needed to watch out for.
In these litigious days, its got to be in bureaucrateze, at arms length, ensuring no possibility of collusion etc etc.
Just a thought
Hmmm...let my imagnation run away with me for a moment...
The CASA-approved dipstick will be made out of certified and traceable wooden dowel, conforming to an ISO standard, from timber produced in an ecologically-friendly and environmentally-sound re-afforestation project in a country whose aviation administration has approved the timber for the production of certified dipsticks. Softwood or hardwood may be used, provided it has been tested by the nationally-designated administrative body which certifies the suitability of the timber for use in manufacture of dipsticks. The certification standard will comply with relevant UN codes and hazmat codes where applicable.
The minimum diameter of the dipstick shall be either thirty-percent of the general average diameter of filling apertures in the aircraft type(s) for which the dipstick is certified or approved, or not greater than 20 millimetres (with a tolerance of plus or minus 0.5mm), whichever is the greater.
Length of the dipstick shall be such that it cannot completely enter the tank of the aircraft type(s) for which it is approved/certified if inadvertantly dropped from an initial position identical to that required for testing the amount of fuel in the tank. If this is impractical, the length shall equal the maximum depth of the tank vertically below the filling aperture plus thirty percent of that distance. No allowance shall be made for use of any securing devices such as loops of string in holes drilled through the non-immersable end of the dipstick. Indeed, unless the manufacturer actually drills such a hole and inserts the string, the addition of such a retention system would constitute an unauthorised modification and immediately render the dipstick unfit for further use in aviation.
Finish of the dipstick shall be such that fuel is unable to permeate into the wood and render the dipstick a potential fire-hazard or source of fumes. High-pressure injection of plastic material or sealing and painting of the dipstick shall be permitted at manufacture only. Dipsticks whose outer protective coating deteriorates shall be either withdrawn from use when the amount of surface exposed to fuel exceeds ten percent of the total immersable surface area or one square centimetre, whichever is the lesser. Under no circumstance shall unauthorised persons or maintenance organisations attempt to re-finish dipsticks with defective or worn coatings.
Calibration of the dipstick shall be done at the point of manufacture and be recorded on the calibration documents furnished with each dipstick. The temperature, type of fuel and specific gravity of the calibration fuel shall also be recorded on those documents. Copies of calibration documents will be required to be carried onboard every aircraft in which the dipstick is used, irrespective of whether the dipstick corresponding to the serial number specified in the calibration documents is carried in that aircraft or not. A log of usages of each dipstick shall be kept in each aircraft as well as a master log of dipstick usage at the home base of the aircraft. Entries will be required to be up-to-date on a two-day basis, that is no logbook of dipstick usage is permitted to be more than two days in arrears, whether the logbook be carried in an aircraft or at the home base of said aircraft.
Dipsticks may be finished in coloured paints with calibration marks complying with ISO9002 standards for Fuel-Measurement Equipment. Under no circumstances may these colours be changed or modified. Dipsticks showing discolouration due to long-term use or attack by fuels shall be condemned and returned to the manufacturer for destruction according to the manufacturer's designated destruction schedule for defective or returned, non-repairable dipsticks.
Manufacturers of such dipsticks shall be required to submit batches for testing to destruction by CASA or a CASA-designated testing facility. No dipsticks from the batch(es) under test maybe sold or pass into the aviation industry in any other way until the testing is completed and the approvals granted. CASA reserves to itself the right to delay indefinitely the testing of batches of dipsticks due to administrative overload without recourse or compensation of any kind being due to manufacturers or operators of aircraft waiting on deliveries of approved dipsticks.
A prominent "Remove Before Flight" label shall be applied to each dipstick to ensure operators do not inadvertantly leave a dipstick in a fuel-filling aperture. The serial number and approval type number of each dipstick shall also be applied in letters and figures clearly legible to anyone with eyesight sifficient for the issue of a PPL at a distance not less than twelve feet.
A users manual with a diagram showing recommended usage practices shall be supplied with each dipstick unit sold. A copy of the manual shall be held in each aircraft in which the dipstick is to be used. A second copy shall be prominently displayed near the re-fuelling receptacles or bowsers such that pilots not familiar with the use of dipsticks can use the dipsticks with a reasonable chance of successfully achieving the desired outcome.
Dipsticks for aircraft with a MTOW exceeding 5700Kg shall be required to have a suitable trolley or other transportation vehicle to ensure they are safely transported around parking-bays, etc. When in use, such dipsticks shall be surrounded with barriers or "witches-hats" markers to indicate that potentially hazardous operations are being carried out. Only personnell having completed a CASA-approved course in dipstick usage, with OH&S accreditation, shall be permitted to use the dipstick, or to go within 30M of such an aircraft when a dipstick is in use. The approved trolley or transporation vehicle shall be equipped with not less than two rotating yellow beacons which shall be illuminated whenever the dipstick is in use.
I could go on, but there's no point in giving CASA too much for free!
The CASA-approved dipstick will be made out of certified and traceable wooden dowel, conforming to an ISO standard, from timber produced in an ecologically-friendly and environmentally-sound re-afforestation project in a country whose aviation administration has approved the timber for the production of certified dipsticks. Softwood or hardwood may be used, provided it has been tested by the nationally-designated administrative body which certifies the suitability of the timber for use in manufacture of dipsticks. The certification standard will comply with relevant UN codes and hazmat codes where applicable.
The minimum diameter of the dipstick shall be either thirty-percent of the general average diameter of filling apertures in the aircraft type(s) for which the dipstick is certified or approved, or not greater than 20 millimetres (with a tolerance of plus or minus 0.5mm), whichever is the greater.
Length of the dipstick shall be such that it cannot completely enter the tank of the aircraft type(s) for which it is approved/certified if inadvertantly dropped from an initial position identical to that required for testing the amount of fuel in the tank. If this is impractical, the length shall equal the maximum depth of the tank vertically below the filling aperture plus thirty percent of that distance. No allowance shall be made for use of any securing devices such as loops of string in holes drilled through the non-immersable end of the dipstick. Indeed, unless the manufacturer actually drills such a hole and inserts the string, the addition of such a retention system would constitute an unauthorised modification and immediately render the dipstick unfit for further use in aviation.
Finish of the dipstick shall be such that fuel is unable to permeate into the wood and render the dipstick a potential fire-hazard or source of fumes. High-pressure injection of plastic material or sealing and painting of the dipstick shall be permitted at manufacture only. Dipsticks whose outer protective coating deteriorates shall be either withdrawn from use when the amount of surface exposed to fuel exceeds ten percent of the total immersable surface area or one square centimetre, whichever is the lesser. Under no circumstance shall unauthorised persons or maintenance organisations attempt to re-finish dipsticks with defective or worn coatings.
Calibration of the dipstick shall be done at the point of manufacture and be recorded on the calibration documents furnished with each dipstick. The temperature, type of fuel and specific gravity of the calibration fuel shall also be recorded on those documents. Copies of calibration documents will be required to be carried onboard every aircraft in which the dipstick is used, irrespective of whether the dipstick corresponding to the serial number specified in the calibration documents is carried in that aircraft or not. A log of usages of each dipstick shall be kept in each aircraft as well as a master log of dipstick usage at the home base of the aircraft. Entries will be required to be up-to-date on a two-day basis, that is no logbook of dipstick usage is permitted to be more than two days in arrears, whether the logbook be carried in an aircraft or at the home base of said aircraft.
Dipsticks may be finished in coloured paints with calibration marks complying with ISO9002 standards for Fuel-Measurement Equipment. Under no circumstances may these colours be changed or modified. Dipsticks showing discolouration due to long-term use or attack by fuels shall be condemned and returned to the manufacturer for destruction according to the manufacturer's designated destruction schedule for defective or returned, non-repairable dipsticks.
Manufacturers of such dipsticks shall be required to submit batches for testing to destruction by CASA or a CASA-designated testing facility. No dipsticks from the batch(es) under test maybe sold or pass into the aviation industry in any other way until the testing is completed and the approvals granted. CASA reserves to itself the right to delay indefinitely the testing of batches of dipsticks due to administrative overload without recourse or compensation of any kind being due to manufacturers or operators of aircraft waiting on deliveries of approved dipsticks.
A prominent "Remove Before Flight" label shall be applied to each dipstick to ensure operators do not inadvertantly leave a dipstick in a fuel-filling aperture. The serial number and approval type number of each dipstick shall also be applied in letters and figures clearly legible to anyone with eyesight sifficient for the issue of a PPL at a distance not less than twelve feet.
A users manual with a diagram showing recommended usage practices shall be supplied with each dipstick unit sold. A copy of the manual shall be held in each aircraft in which the dipstick is to be used. A second copy shall be prominently displayed near the re-fuelling receptacles or bowsers such that pilots not familiar with the use of dipsticks can use the dipsticks with a reasonable chance of successfully achieving the desired outcome.
Dipsticks for aircraft with a MTOW exceeding 5700Kg shall be required to have a suitable trolley or other transportation vehicle to ensure they are safely transported around parking-bays, etc. When in use, such dipsticks shall be surrounded with barriers or "witches-hats" markers to indicate that potentially hazardous operations are being carried out. Only personnell having completed a CASA-approved course in dipstick usage, with OH&S accreditation, shall be permitted to use the dipstick, or to go within 30M of such an aircraft when a dipstick is in use. The approved trolley or transporation vehicle shall be equipped with not less than two rotating yellow beacons which shall be illuminated whenever the dipstick is in use.
I could go on, but there's no point in giving CASA too much for free!