CAO 100.5 Amendment 13
 

From AMROBA...

CAO 100.5 Amendment 13 will become effective on 1st August 2013.

This CAO covers revised requirments for items maintained under AD/INST/8 & 9 and AD/RAD/43 and introduces a number of additional requirements in the form of Pitot static, encoder and fuel Qty checks similar to the way things used to be.

More importantly, and Of particular concern is the following wording which may have the effect of precluding the use of maintenance under Schedule 5 which is used by the majority of General Aviation Aircraft.

REPEALED
Quote:
9.1 For the purposes of subregulation 38 (1) of the Regulations, CASA directs each person who is the holder of the certificate of registration for an Australian aircraft to comply with the requirements specified in the Airworthiness Limitation Section of the maintenance manual of the aircraft for which the person is the holder of the certificate of registration.


NEW
Quote:
9.1 For subregulation 38 (1) of the Regulations, CASA directs the registered operator of an Australian aircraft to comply with the maintenance requirements for the aircraft and its aeronautical products, including life-limits, as established under the approved design for the aircraft or product.
Note Contravention of a CASA maintenance direction under this subsection is a strict liability offence under regulation 38 of the Regulations

The sudden and unexpected abolition of Schedule 5 may have huge ramifications for owners and the viability of General Aviation in this country.

It is hoped CASA will clarify this situation before 1st August.

Does anyone have any further information regarding this?

Yes! I have the inside word from a little birdie, no not the Townsville or Leigh Creek refuellers either, that there is an inadvertent ooops and they did not mean to sweep all things into that statement.

A redraft is rapidly being produced. Lets hope they get it right this time round.

Stand by for the revision.

My take when I read it was it was only scooping up pitot static and such related things, but if you read it closer it scoops all things from the spinner to the tail light. That was not the intention apparently.

Some folk were on the ball. :ok:

Struth, if this comes into effect it means goodby to any engine extension. There are a lot of PVT/AWK aircraft out there with calendar expired engines. There are a lot of perfectly good engines out there that have run beyond manufacturer TBO.

With SIDS and this, I am beginning to think GA is is going to shrink away even more.

Hence the rewrite, an unintended consequence :ouch:

Folks,
Jaba has got it right, thanks to "an overwhelming avalanche of (aviation) public opinion", Herr. Boyd is having the instrument re-written to remove the unintended (but were they really unintended --- read the drafts of the proposed GA maintenance rules) consequences.
You will probably find something on AMROBAs web site, they have been very active in this (and many other airworthiness regulatory atrocity) matter.
Tootle pip!!

Schedule 5 on the way out
 

CASA have been hinting for a while (e.g. via ageing aircraft seminars) now that Schedule 5 is on the way out.. perhaps this particular effort jumped the gun, hence the re-write, but I don't think pvt/airwork CoR holders can expect to operate on Schedule 5 forever, particular for newer Cessna's etc where there is a well established manufacturer maintenance schedule.

I thought that the main intent of Schedule 5 is meant to be there for aircraft where the manufacturer maintenance schedule is non-existant or deemed deficient :confused:

Duncan G et all,

You should have a look a FAAs FAR 43, Appendix D, the FAA annual inspection schedule --- and compare it to Schedule 5.

Low and behold, you will find most of Schedule 5 is exactly the same, with some minor bits of Australian rubbish appended, which isn't surprising, because Schedule 5 was copied from FAR 43, Appendix D.

But Schedule 5 is not what it says it is, it is not a system of maintenance, (part of the Australian nonsense) it is an inspection schedule --- and you need the data to actually carry out the tasks on the Schedule ---- and this has been the huge mental block suffered by CASA re. maintenance of US built (and some other countries) FAR 23 light aircraft --- by far the majority of aircraft on the Australian register.

The US system is delightfully simple, where FAR 43, Schedule D is applicable, you must carry out an annual inspection, you do that using Schedule D, the manufacturer's MM and the whole FAA AC library, as applicable, but particularly AC43.13A & B.

The latter being the bible for the basic maintenance and repair of light aircraft.

As the manufacturer's aircraft is certified under this FAA system, by and large the manufacturer's MM only covers matters that are specific to the make and model of aircraft ---- it is not a manual that repeats all the standard practices, techniques etc that are in the ACs, particularly AC 43.13A & B.

Then some clown here looks at the typical US MM for a light aircraft and declares it "deficient", which it is not, in context of how the aircraft was certified, including the manufacturer's instructions for continuing airworthiness.

So, the proper way to comply with the aircraft certification, including (even when it is registered in Australia) instructions for continuing airworthiness, is to use Schedule 5 (except the Australian-isms) annually or every 100 hours, using the aircraft's MM for specific details and settings, rigging etc., and using the applicable AC.s for how to actually carry out the tasks.

It is the longstanding lack of understanding in Australia, as to the full ramifications of the certification of these USA built aircraft, that is deficient, not the aircraft's MM.

To make it easier, some years ago, the then "appropriate person" in CASA produced a Legislative Instrument to automatically make all FAA ACs and the equivalent from other countries, approved data for the continuing airworthiness of the relevant aircraft.

This meant that ACs didn't, any longer, have to be approved individually for each maintenance organisation.
ie; One smart bloke in CASA, with the right delegation, pulled the plug on the whole "approval" racket, including the costs, aggravation and delay inherent in almost any dealings with CASA.

His successor renewed the instrument several times.

Now, under the present crew, the automatic approval of documents such as AC 43.13A & B is back to case by case approval ---- what a great make work exercise. $$$$$$

In context, the MMs that those in CASA declare deficient are no such thing, it is the Australian rules for the proper processes to ensure continuing airworthiness of the kind of aircraft we are talking about here that are seriously deficient --- and it will be far worse under the proposed new rules.

Worse, because it completely ignores the basic certification the aircraft, including the instructions for continuing airworthiness, which are all part of the C.of A.

Indeed, it can be legally argued that, under the present Australian legislation, a very large number of aircraft in Australia have an invalid C.of A, because the manufacturer's directions for continuing airworthiness are not being complied with, because Australian regulations do not allow compliance.

While all this probably induces brain ache, it is fundamental to the problems of proper and adequate maintenance of many light aircraft in Australia.

Tootle pip!!

Leadsled,

I feel some sense of enlightenment from reading your post - thank you :)

e.g. the Cessna 172R MM says:
Now I understand that Sched 5 is based on 43 App D, that makes more sense :ok:

duncan g said:Is anyone able to point to the provisions of the regulations that manifest that intent? (Individual’s assertions as to what was intended don’t count.)

In any event, is anyone able to point to any airworthiness problem that has resulted from maintaining an aircraft in accordance the schedule of maintenance at Schedule 5 of the CARs? (When I say ‘in accordance with’, I don’t mean pencil-whipping inspections that haven’t happened. Those kinds of inspections result in the same outcome, whether by reference to Schedule 5, the manufacturer’s maintenance schedule, an approved system of maintenance or the astrologer’s advice in the local tabloid.)

Hi all, just new here and reading this thread and I was just as horrified to see the mistake when reading the new legislation early last week. This potentially would have grounded all GA fleet that operate under S5 on Aug 1st.

Reading the paragraph below from the new reg I take it to mean things like as an example, all rubber hoses in the aircraft eg fuel lines. Trim actuators, flap motors, speed brakes, ect, ect. Glad that got sorted. Sounds like they blamed the legal department for the draft.

Paragraph 9.1
For subregulation 38 (1) of the Regulations, CASA directs the registered operator of
an Australian aircraft to comply with the maintenance requirements for the aircraft
and its aeronautical products, including life-limits, as established under the approved
design for the aircraft or product.

So big question is when CASA get the maintenance sorted out for LCRPT or Part 135 and they want everyone to go on manufactures maintenance, I want to know, will this mean that all work previously done under S5 for aeronautical products, including life-limits have to be reversed before switching over to manufactures maintenance? What a big expensive time consuming exercise that's going to be.

Also if they want us all to go to manufactures maintenance and with Cessna this means part of the 100 hrly gets done at the 50 hrly then that really leaves the guys in the bush up the creek. Now they do the 50 hourly oil/filter change themselves and take it down for the 100 hourly. Isn't it going against the problem of aging aircraft as if a guy in the bush has a 2 to 3 hour ferry each way to get a 50hrly done he will be burning up 10% of the M/R just going to and from maintenance and running up TT unnecessary, let alone the cost of it all. It will be the final nail for bush operators. :sad:

Would like to know how the figures for accidents caused by Schedule 5 maintenance stack up to prove the need for change if it is a safety issue.

MIck Stuped,
Go back and have a re-read of my posts on the subject.
Most MM for US light aircraft are NOT comprehensive, because they are not intended to be, they assume the use of FAR 43, Appendix D (known here as Schedule 5, more or less) plus the FAA AC library, as required, but particularly AC43-13A&B.

All the detailed information on AC43-13A&B is not repeated in the manufacturer's MMs.

Thus, those in CASA don't (or don't want to) understand, declare my MMs "deficient" ---- when they are no such thing

Some current reading: Maintenance mayday ? screw-up or conspiracy? Opinion | Pro Aviation

Tootle pip!

.........and to add to your woes............

What worries me the most is MIF, Maintenance Induced Failure.

I had a case on the weekend where I diagnosed what I believe to be 2 induction leaks INDUCED by the LAME doing a 100hrly injector clean during an annual inspection.

The damned injectors should NEVER have been touched, they are flushed 100% of the time with a great solvent and unless a bit of debris finds its way there the injector is not at risk. So to get the injector out, the intake flanges are removed, reset in place and the gasket not replaced.

Had the owner not been astute, equipped with an EMS and not been to the worlds best training course, he would have been none the wiser, and several hundred hours down the track wondered why the life spad of some cylinders was not the same as others.

Doctors bury their mistakes, and often Maintenance orgs do too, well they replace them and you pay and never know.

So maintenance or extra unwarranted maintenance as it should be considered is the likely cause of problems. Mike Busch is worth looking up and reading the hundered or thousands of examples he has noted about this. But despite this CASA want to apply even more. Because they know better.

About time the federal government did something about trans Tasman love, and sub contracted the whole show out to the NZ CAA.

Would be cheaper and more effective :ok:

Ohh and that Phelan artile = http://www.smileyvault.com/albums/us...lOnTheHead.gif

casa just do not get it!!!!!!!!!
 

Well again, casa screw up abounds at best.

At worst, a distinct hit at our industry

Which is it John - maybe a reminder of the Brisbane AMROBA debacle.

CAO 100.5 | Assistance to the Aviation Industry

Jaba,
Interesting you should bring up the subject of maintenance induced failures.

Although "maintenance" is only a minor contributor to accidents in light aircraft (actually less than in large aircraft), a good proportion of those failure (no, I can't give you statistics --- just my recollection of having read many hundreds of accident reports) are "human failures", not a failure of the component itself --- ie; re-assembly was not carried out correctly.

In the early days of WW11, there was an interesting study done by the RAF, as the result of analysis of failure immediately after maintenance. This is the earliest paper, of which I am aware, that is the basis of "on condition" maintenance.

Analysis of the records showed a history of in service failure rates receding after the first 10 hours or so. A lot of "maintenance" was changed to what we now call "on condition" --- a message that is not part of the mindset of a hard core of the "iron ring" in CASA, to this day.

Can you imagine how airline costs would skyrocket, it they were subject to the same nonsense that some in CASA (despite years of experience to the contrary) wants to once again impose on GA.

With a few exceptions, all the life extension programs for engines in charter have already gone, despite (in my case) some 40 years experience in the validity of on condition overhauls of piston engines.

There is no shortage of proponents in CASA ( and some of their conflicted supporters in the industry) for axing AD/ENG/4.

Tootle pip!!

Running piston engines on condition in a commercial environment should never have been approved by CASA.
The logic is beyond my understanding.

The requirements for pressure instruments is nothing new.
Yada yada, LAME's don't know as much as pilots trained by GUMI bears

And therein lies one of the problems. Just because you don’t understand something doesn’t make it wrong. :=

Where are your data to prove that engines on 'on condition' maintenance or beyond manufacturers’ recommended TBO fail more frequently than those that aren't?

Owen,

Don't you mean DCA/DoT/CAA etc and CASA. The history goes back to the 1940/50s

You really have some conceptual problems, don't you, including with, it would seem, evidence based decision making.

Indeed, perhaps you would like to inform us of the basis for your regular decision making, or how you form your views, do you read the runes, consult Athena Starwoman, or analyses the Astrological Signs, or use beer goggles??

Just for starters, the engine manufacturers, with which I am most familiar, do not publish TBOs, they publish RTBO ---R for recommended being the critical word.

If you bothered to delve in to published data, including from the manufacturers ( apart from assisting your understanding) or, perhaps, just used a bit of unintuitive deduction, given that the operating environments for engines vary enormously, suggesting that there is one magic number, beyond which the engine should no longer be used used, or will be still operating satisfactorily --- makes no logical sense --- except, apparently, to you.

Indeed, in some circumstance, in severe operating environments, or at the opposite end of the spectrum, engines that are not regularly used, overhauls before RTBO may be the order of the day.

One size does not fit all.

In fact, CASA and its predecessors have quite a lot of data on reliability of engines run on engine life extensions under the "old" rules -- as Creamie anticipates, there is no operational outcome degradation, no increase in risk (or reduced safety, if you insist on using those word) , and the operating economies of a 2700 TBO v. 1700 RTBO even you should be able to work out.

Regularly used O-200 are quite happily running well over 3000h TBO.

Despite this evidence, collected over 20/30 years, just about all the life extension programs for aircraft used in charter/RPT have been withdrawn, and I am aware of several applications that have been rejected without explanation by CASA.

Tootle pip!!

PS: I suppose you know that most aviation turbine engines run on condition, and the varying commercial lives of individual engines in a fleet nominally operating under similar condition, makes an interesting engineering economic study.

Owen

I take that rather seriously. LAME's often do know more than pilots but, there are some pilots out there that are streets in front of the LAME's, most of them, and this one in particular which I referenced above is gobsmacked now at the absurd advice coming from the Aircraft Manufacturer (one of the big 4). I support his stance, it is remarkable.

We give our students a 25 question test. The results after thousands of students all fall in the same parts of the bell curve every time. You would be surprised where the LAME's and A&P's score, and alarmed where the FAA and CASA folk score.

Can I invite you along to a really good weekend of education in November? See for yourself. Money back guarantee. :ok: And a bonus, $1000 if you provide data that proves anything we teach is incorrect. (Walters Money :E)

Well sorry to upset the engine Gurus with dissident thoughts.