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[QUOTE=LeadSled;9966899]Conned Rod,
Again, what on earth are you talking about?? I have never been "REMOVED" from anything, aviation-wise. Neither, you dopey person, have I suggested that no regulation is required, only that Australian aviation is grossly over-regulated, compared to any comparable country, that CASA seeks to micro-manage the whole aviation sector, and this is a very major factor in the parlous, approaching terminal state of GA in Australia, compared to any comparable country. And Bend a lot, I am aware of what you refer to, but I have never seen a stipulated training course of any kind, to carry out Schedule 8 maintenance. And I listen to the rumblings of various CASA persons from time to time. I am NOT referring to any aircraft maintained under 42ZC(4)(e) home built, to use an inaccurate term. That particular "training course" is, in my opinion, almost a waste of time, and includes entirely irrelevant material, but it is a "nice little earner". I am not aware of any "CASA Approved" syllabus and process, and, quite frankly, any LAME who signed his name to anything that, in any way, suggests he has determined and approved a satisfactory level of competency for a person whose only formal qualification is he or she is a class person entitled to do Schedule 8 maintenance, that would be putting his head on the chopping block, in terms of potential This us because your abillity to listen and learn is one of your many failures. Just because you dont know it dosnt mean it dosnt exist and dosnt happen. Ive had to sign of many pilots in this regrads. So have many lames. But im guessing in your mind im lieing and making it up. I do know at this present stage is moves abound to remove shed 8 and no pilot maintenance will be allowed. As for your comment about a lame doing a 5 year apprenticeship. 12 months to get a bus driver in the seat from the start to the seat. 10 years to get a kid of the street to a lame that can do just about anything. Your comments are one of the reasons that lames are now considered a rare species. At the end of the day poeple like yourself will loose. Toot toot |
Originally Posted by Bend alot
(Post 9966637)
LeadSled.
REG 42ZC "(a) CASA or the authorised person, as the case may be, considers are necessary in the interests of the safety of air navigation; and" Is one thing they use - there is another buried in the regs that says some thing like maintenance is only to be carried out by "appropriately trained" persons. Gee what you think that showing him the regs he will believe you. No never. He say to myself i cant help it if you cant read. So leadie how about you actually reading. Or better still as your are so much more intelligent than us lame and your an engineer of sorts cause you have gone to uni. Why dont you go do the lame exams become a lame and then you can do all your own maintenance tell the world how good you are. Toot toot |
Originally Posted by LeadSled
(Post 9965765)
CIVIL AVIATION REGULATIONS 1988 - SCHEDULE 8 Maintenance that may be carried out on a Class B aircraft by a person entitled to do so under subregulation 42ZC(4)
Item 4 ---- is interesting, it was explained to us that this meant what it said, only defective safety wire, ergo replacing those oil filters that have safety wiring are out of the question, because your are installing new safety wire, having replaced the filter. Not replacing anything defective. Replacing of oil filters is covered by AD/ENG/4 which authorises a pilot to do so (IAW the manual of course) since the manual calls for lockwire the pilot is authorized to lock the filter. And so it goes on ---- all these tricky bush lawyer interpretations made by people who have the power to make you life very miserable. Like what does "complete jacking" mean? Interestingly the C172R manual says jacking of both wheels simultaneously using the built in jack pads is not recommended and that standard practice is to jack one wheel at a time. The pièce de résistance is washing a windscreen, unless something has changed since last time I looked, no light aircraft manufacturer (FAR 23 piston) has published approved data to wash a windscreen, but we had quite a celebrated case here, a while back. The inspector insisted that you could only wash a windscreen by entering a defect (vision obscured??) in the MR, then proceed via the Manufacturer's Instructions, which don't exist, which means a CASR Part 21M(old CAR 35) approval. with lots more rigmarole ---- and it's not on Schedule 8. Windshield cleaning is covered in the "care and maintenance" section of the POH/AFM and is also in the servicing section of the Maintenance Manual. It usually includes approved products and detailed instructions. This is true for Cessna, Piper, Beech, Mooney, Cirrus, American Champion, Grumman and Partenavia. I cant confirm the rest. All in the true spirit of making life as difficult and expensive as possible. I have had the occasional spirited discussion with an FAA inspector in years gone by, but with only a couple of exceptions, they have never had an acrimonious "big stick" overtone from the opening words, quite the reverse to the all to common atmosphere here. The net outcome of all this nonsense is a complete lack of respect for just about anything from CASA, which is a pity, because all the things that are actually important get lost in the piles of garbage.= And much is done behind locked hangar doors, some of which probably shouldn't be, but will never appear in the aircraft records. The saving grace is the great percentage of owners and pilots are quite sensible, so a real risk arising is always possible, but not all that probable. May be we should be grateful that CASA at least allows us to refuel our own aircraft, and check the oil?? And I have had multiple occasions, over time, to threaten a LAME with legal proceedings for recovery, for such as signing off an AD that was not done, signing off required maintenance that was not done, and in one case, fitting the wrong model of O-470 to a C-182. Tootle pip!! Conned Rod (or whatever) ---- would you like to explain to us all the CASA regulations that require training to do Schedule 8 maintenance, as you have brought the subject up. |
REG 42ZC "(a) CASA or the authorised person, as the case may be, considers are necessary in the interests of the safety of air navigation; and" Conned Rod, Might I suggest it is your apparent inability to read, and fully comprehend, that is part of the problem --- go back and read what I have actually written. Just because you believe you have signed off pilots to do Schedule 8 maintenance does not make that proof that what you did has any legal standing. Do you have a detailed written and lawful direction from CASA, if you do, why not post it here? What legal instrument do you hold to deliver such courses? No such requirements are mentioned in the CAAP covering Schedule 8 maintenance. Nowhere in the CASA documents, that I have ever seen, does it lay down a process for delivering a course of training, to achieve prescribed competency standards, how those competency standards will be examined, and what form of “authority to conduct Schedule 8 maintenance” will flow to candidates meeting the prescribed competency standards on completion of the prescribed course. If you do find one, in a MOS or wherever, please let us all know. As for moves to remove Schedule 8 entirely, a certain brand of LAME and a union has been on about that for years, fortunately the tide is in the opposite direction. But it does raise a very interesting issue, the matter of “rule of law” versus “rule by law”, and if you do not understand the difference, please do some homework:< https://www.ruleoflaw.org.au/> Because aviation law in Australia is all too well recognised as prescriptive in the extreme, complex, convoluted and contradictory, “rule by law” is the order of the day, with “an officer of CASA” all too often "laying down the law", when what is forthcoming is his or her version of what the law should be, but isn’t, a view generated by personal prejudices, but dressed up as “the law”, “CASA requires ------“ etc. Or, even worse, for years CASA initial training of AWIs in Canberra taught material that was completely contrary to what the law actually said, in quite basic ways, in that case a bit hard to blame individual AWIs. How do I know, because I have sat in and looked and listened. And the poor sod on the receiving end of this treatment often has little option by to comply, they don't know what "the law" is, and because of the “asymmetric power imbalance”, ie; vague or so not so vague threats of what will happen in the event of non-compliance ----- generally a livelihood threatened by an “aggressive audit” or something similar. And, sadly, these threats are very real. Or there is the one who is all too happy to comply, such is their jaundiced view of "owner or registered operators" who are actually responsible for completion of maintenance, not the LAME. That is where I expect to hear " CASA requires ----" or "CASA does not permit owners to supply their own parts". Interestingly, it was at this time that the CAA legal department had come up with the concept that an aircraft release to service (Maintenance Release in Australia) would deem an aircraft serviceable for the period of such release, they were told in no uncertain terms that we would no longer release aircraft if that was to be the ruling. 2.7 Unless otherwise indicated in the table, where the table requires a thing to be inspected, the inspection is to be a thorough check made to determine whether the thing will continue to be airworthy until the next periodic inspection. Sadly, there have been some significant prosecutions of LAMEs based on 2.7, the worst (to my knowledge) involving a fatal some 80 hours into the “new” MR. You will not find anything like that in FAR 43 Appendix D, from which Schedule 5 was copied, that is an added “Australianism”. Lead Balloon, I believe you are correct about AMROBA, such is the memory of a senile old man. But I do remember being at a CAA(prior to CASA) conference in Darwine in 1992 ish when the "new" regulations, at that time, were being discussed. Amongst these was the removal of LAME privileges to carry out 100 hour/annual under the auspices of their own licence. It was told at the time this was as a direct input from the maintenance organisations. Few things better demonstrate the need for the proper "rules" for regulatory development to be enforced on CASA. These, in brief, require a proper definition of the risk to be mitigated, why a rule, as a last resort is necessary, and proper and genuine benefit/cost justification of the proposed rule. If you want all the details of how to do it, the Office of Best Practice Regulation (OBPR) is the place to start, it just that CASA ignores these guidelines, claiming the Civil Aviation Act effectively prohibits their application. Tootle pip!! |
Originally Posted by Bend alot
(Post 9966637)
LeadSled.
REG 42ZC "(a) CASA or the authorised person, as the case may be, considers are necessary in the interests of the safety of air navigation; and" Is one thing they use - there is another buried in the regs that says some thing like maintenance is only to be carried out by "appropriately trained" persons. CASA ruling 2/2003 states: Persons who only carry out maintenance in their capacity as pilots are not ‘maintenance personnel’ within the meaning of CAR 214. 8 Accordingly, CAR 214 does not require an operator to make provision for the instruction of pilots. So no training is required to conduct pilot maintenance |
Folks,
A brief addendum to my last, above: It is a complete solution to the cost of 100 hour/annual inspections for may private aircraft. If I was to forecast, particularly given the new and quite revolutionary FAR 23, I would expect a considerable push in Australia to adopt the Canadian Owner Maintained C.of A system, which was, after all, an Australian CAA proposal in the first place, picked up by Don Spruston (as in the Forsyth Inquiry) when he was still in Transport Canada. And promptly actioned. It has been notably successful in giving new life to the bottom end of non-sports aviation, with absolutely no adverse safety outcomes at all. Because of geographical differences, I think it would be far more widely used in Australia than Canada. Tootle pip!! |
Conned Rod,
Might I suggest it is your apparent inability to read, and fully comprehend, that is part of the problem --- go back and read what I have actually written. Just because you believe you have signed off pilots to do Schedule 8 maintenance does not make that proof that what you did has any legal standing. Do you have a detailed written and lawful direction from CASA, if you do, why not post it here? What legal instrument do you hold to deliver such courses? No such requirements are mentioned in the CAAP covering Schedule 8 maintenance. Nowhere in the CASA documents, that I have ever seen, does it lay down a process for delivering a course of training, to achieve prescribed competency standards, how those competency standards will be examined, and what form of “authority to conduct Schedule 8 maintenance” will flow to candidates meeting the prescribed competency standards on completion of the prescribed course. If you do find one, in a MOS or wherever, please let us all know. Wtf. I cant believe you believe your own bs. Really. The fact it written on an approved forms then submitted to casa for approval. What this dose not count in your eyes. But as i said i might be making it all up. NOT. !! Just because you dont know dose not mean it cant or dose not happen. You worked in a shelted workshop for how long ? |
I can’t answer for previous posters, but in my case I’ve delivered plenty of training for pilots on how to change oil and oil filters and how to change/remove/check/refit spark plugs on aircraft piston engines. (My observation is that many pilots are usually able to change a light bulb, without the benefit of my training.)
Naturally I tell people to use shifting spanners, hammers and multi-grips to do the job. Using the correct sockets and spanners and calibrated torque wrenches is soooo tedious! Tighten until the veins in your forehead pop and that’s about right is my motto! I’ve always found lockwiring to be difficult, so I now suggest that pilots use solder as it’s nice and soft. The paperwork is beyond me, so nothing goes in the maintenance release. My expensive kit of calibrated torque wrenches, thread chasers, lockwire pliers, rolls of lockwire, anti-seize, plug gap gauge and tool, multimeter, plug gaskets, sockets, spanners and drives, and the smudged and dog-eared pages of approved maintenance data are all just for ‘show’ because I haven’t a clue what they are for. I’ve never mentioned the regulatory requirements for authorisation to carry out maintenance, the use of approved maintenance data, the recording of damage and defects or the certification of completion of maintenance. Rules schmoolz is my motto! Yet the various aircraft on which I and my ‘trainees’ have frequently inflicted these amateur atrocities - and trust our lives - are still flying, years later. My address and phone number are in the book, so I’m surprised I haven’t been arrested for delivering ‘unapproved’ training. Should I hand myself in to the authorities, Conned? |
Originally Posted by Clinton McKenzie
(Post 9967471)
I can’t answer for previous posters, but in my case I’ve delivered plenty of training for pilots on how to change oil and oil filters and how to change/remove/check/refit spark plugs on aircraft piston engines. (My observation is that many pilots are usually able to change a light bulb, without the benefit of my training.)
Naturally I tell people to use shifting spanners, hammers and multi-grips to do the job. Using the correct sockets and spanners and calibrated torque wrenches is soooo tedious! Tighten until the veins in your forehead pop and that’s about right is my motto! I’ve always found lockwiring to be difficult, so I now suggest that pilots use solder as it’s nice and soft. The paperwork is beyond me, so nothing goes in the maintenance release. My expensive kit of calibrated torque wrenches, thread chasers, lockwire pliers, rolls of lockwire, anti-seize, plug gap gauge and tool, multimeter, plug gaskets, sockets, spanners and drives, and the smudged and dog-eared pages of approved maintenance data are all just for ‘show’ because I haven’t a clue what they are for. I’ve never mentioned the regulatory requirements for authorisation to carry out maintenance, the use of approved maintenance data, the recording of damage and defects or the certification of completion of maintenance. Rules schmoolz is my motto! Yet the various aircraft on which I and my ‘trainees’ have frequently inflicted these amateur atrocities - and trust our lives - are still flying, years later. My address and phone number are in the book, so I’m surprised I haven’t been arrested for delivering ‘unapproved’ training. Should I hand myself in to the authorities, Conned? Yes and thats why you were removed from your position within casa. Toot toot |
Wtf. I cant believe you believe your own bs. Really. The fact it written on an approved forms then submitted to casa for approval. What this dose not count in your eyes. But as i said i might be making it all up. NOT. !! Just because you dont know dose not mean it cant or dose not happen. You worked in a shelted workshop for how long ? What approved forms, give us a reference, what CASA "approval", based on what regulation, and why is it not mentioned in the CAAP for Schedule 8. De-identify it and post it!! I didn't say you are "making it up", I am saying: What you are doing has no legal basis, and I am saying you are really sticking your neck out, in terms of legal liability, for purporting to find somebody competent to unstated standards, training delivered under what legal instrument, etc., and what your qualifications are (just being a LAME doesn't cut it) to deliver such training. Let me put it another way, if I go out tomorrow, and work on my aircraft, something clearly within Schedule 8, and I have never done ANY CASA approved course, which I have not, am I committing and offense, and if so, against what regulation. Tootle pip!! PS: And just to remind you again, you have not substantiated your assertions that I was "removed" from something aviation related (or anything else, for that matter) Or explained your AOPA complaint, or what the heck 200% si is?? |
OK then, Conned: I’ll front at the AFP HQ here in Canberra and hand myself in.
And there was me thinking that I terminated my contract with CASA, in accordance with the terms of that contract, because I didn’t like the job. For all these years I’ve been in denial about the unsavoury maintenance training controversy. Now, all has been revealed. Well done Conned! |
Where do you guys find the spare time for all this posting for this discussion and others, are you posting while at work or something?
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Private Owner Versus Charter/Airwork Pilot
It would appear that a Private Owner Pilot can do what they (the pilot singular or plural, male, female or other gender(s) as applicable) likes, within the constraints of Schedule 8.
A pilot working for an organisation that has an AoC would not be able to do the same as the Private pilot, unless an approved/authorised person has deemed them (the pilot singular, male, female or other gender(s) as applicable) competent to carry out the task as listed singularly, and by Job Number. |
Wtf. I cant believe you believe your own bs. Really. The fact it written on an approved forms then submitted to casa for approval. What this dose not count in your eyes. But as i said i might be making it all up. NOT. !! Just because you dont know dose not mean it cant or dose not happen. You worked in a shelted workshop for how long ? Thank you Leadsled for informative interesting posts. |
Originally Posted by Eddie Dean
(Post 9967483)
It would appear that a Private Owner Pilot can do what they (the pilot singular or plural, male, female or other gender(s) as applicable) likes, within the constraints of Schedule 8.
A pilot working for an organisation that has an AoC would not be able to do the same as the Private pilot, unless an approved/authorised person has deemed them (the pilot singular, male, female or other gender(s) as applicable) competent to carry out the task as listed singularly, and by Job Number. |
Clinton
Was humpty dumpty pushed or did he jump. The end was tne same he was removed from the wall. I let you make your own conclusions from that. Some of use know the truth. I did find it amusing you didnt use your ultra ego though. If the form is approved from casa. Im approved from casa. Then casa approves the from that i have filled in. Then of course its not approved. This is not a lop course which has no approvals and training by non approved persons. Big difference. Toot toot. |
Where do you guys find the spare time for all this posting for this discussion and others, are you posting while at work or something? In part because I am stuck at home with a bleedingly obstinate cold, and partly because my views on the subject accord with your handle, I much prefer the truth, the facts, to the alternative. I have found facts, as far as the facts can be determined, a good starting place, and, of course, sticking with the truth means I don't have to have a good memory. I can't speak for anybody else. Tootle pip!! |
Originally Posted by Aussie Bob
(Post 9967489)
Conned, your hilarious! If it came to the crunch I would take Leadies legal writings over yours any day.
Thank you Leadsled for informative interesting posts. The difference is i and others work with these regs on a daily basis. Not in an out as we wish. We not fools even if you like to treat us such. To the point we are exained on av law in regards to maintenance and other. Toot toot |
Bob.
As i recall this is the same person that stated that lames filled out the M/R incorrectly. This was strange by someone that by their own admission had never filled one out or certified any job within a check or any category certifications. Yet even though i average 2 M/R issues a week i have no idea. Come on. Not only that every time we get a casa adult they look at the work packs an the M/R book. But then again i guess they dont know how to do it as well so dismissed the above. Toot toot |
If the form is approved from casa No more assertions, show us where the CASA Approved Form can be found on the CASA web site, or is that your little secret with CASA?? In my opinion, given you reluctance to provide any proof, I can only think you are, indeed, making it up. Prove us wrong, produce the proof. Tootle Pip!! PS: Old mate of mine, quite senior now in CASA "airworthiness" , one of the survivors, really, has never heard of any requirement for CASA mandated training and approval for Schedule 8 training, so maybe it's top secret in CASA?? |
[QUOTE=LeadSled;9967545]Conned Rod,
No more assertions, show us where the CASA Approved Form can be found on the CASA web site, or is that your little secret with CASA?? In my opinion, given you reluctance to provide any proof, I can only think you are, indeed, making it up. Prove us wrong, produce the proof. Tootle Pip!! As ive said to bob. You believe in what you wish. I dont have a thing to prove to yourself. Ive just done 4 guys and have another 2 in thext few weeks. However i might have to tell them that its all a waste because you say so. Ill also call the the local office and tell them as well I suggest your time would be better in understanding what is written in shed 8 in particular how to jack an aircraft and requirements in doing. Clearly you do not understand this its number 1 on the list. Toot toot ... |
It is curious that I have been told by a LAME, a very good friend of mine that in order to legally do pilot maintenance on my aircraft I need to do it in conjunction with a maintenance organisation where I have done a basic course and have my name on a list stating such.
I wonder if he and Connedrod both have the same AWI? Anyway, my name is not on his or anyone else "list" and I am happy to do the stuff on the "pilots maintenance" list without this fabled course. Private hanger of course! My friend, as always is very helpful if I get stuck. |
Aussie Bob there are more than 1 AWI with that view, that they pressure persons on to "be trained"
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Originally Posted by Aussie Bob
(Post 9967575)
It is curious that I have been told by a LAME, a very good friend of mine that in order to legally do pilot maintenance on my aircraft I need to do it in conjunction with a maintenance organisation where I have done a basic course and have my name on a list stating such.
I wonder if he and Connedrod both have the same AWI? Anyway, my name is not on his or anyone else "list" and I am happy to do the stuff on the "pilots maintenance" list without this fabled course. Private hanger of course! My friend, as always is very helpful if I get stuck. |
Originally Posted by Connedrod
(Post 9967686)
Ummm most definitely not the same awi. Trouble here is poeple that think they know just dont know it all.
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Progressive,
A comment about "servicing", so helpfully brought to our attention by CASA persons re. Schedule 8. There is no such thing as "servicing" in Australia, just maintenance. Doing a daily inspection is "maintenance". Checking the oil is "maintenance". Adding fuel is "maintenance", and so it goes on. AND --- all "maintenance" must be conducted to approved data. Many of us have argued, long and loud, that "servicing" should be as per the FAA, which is what you are quoting, and what we had in draft regulations (Part 91/135 and 43) in 1999. Thus, as the windscreen washing does not form part of the Manufacturer's Instruction for Continuing Airworthiness (not Servicing) there is no approved data. This is where the ratbag Australian approach to mindless "compliance" trumps common sense, commons sense being a very uncommon commodity in Australian aviation regulation. But, of course, CASA will not even accept that the AFM, by whatever name, forms part of the certifications of an aircraft, and regularly purports to direct operators to diverge greatly from POH/AFM procedures. If one or more manufacturer (it has always been in most FAR 25 aircraft MM) has now put said "approved data" in the MM of FAR 23 aircraft, as opposed to servicing, that is good, because it remove one item of harassment. Tootle Pip!! PS: Re. Jacking, way back I was only quoting the CASA "interpretation" as per the traveling roadshows, of Schedule 8, to point out the absurdities of CASA interpretations, not my reading of Schedule 8, but Conned Rod seems to have have ongoing problems with the written word. |
Originally Posted by LeadSled
(Post 9967872)
Progressive,
A comment about "servicing", so helpfully brought to our attention by CASA persons re. Schedule 8. There is no such thing as "servicing" in Australia, just maintenance. Doing a daily inspection is "maintenance". Checking the oil is "maintenance". Adding fuel is "maintenance", and so it goes on. AND --- all "maintenance" must be conducted to approved data. Many of us have argued, long and loud, that "servicing" should be as per the FAA, which is what you are quoting, and what we had in draft regulations (Part 91/135 and 43) in 1999. Thus, as the windscreen washing does not form part of the Manufacturer's Instruction for Continuing Airworthiness (not Servicing) there is no approved data. This is where the ratbag Australian approach to mindless "compliance" trumps common sense, commons sense being a very uncommon commodity in Australian aviation regulation. But, of course, CASA will not even accept that the AFM, by whatever name, forms part of the certifications of an aircraft, and regularly purports to direct operators to diverge greatly from POH/AFM procedures. If one or more manufacturer (it has always been in most FAR 25 aircraft MM) has now put said "approved data" in the MM of FAR 23 aircraft, as opposed to servicing, that is good, because it remove one item of harassment. Tootle Pip!! PS: Re. Jacking, way back I was only quoting the CASA "interpretation" as per the traveling roadshows, of Schedule 8, to point out the absurdities of CASA interpretations, not my reading of Schedule 8, but Conned Rod seems to have have ongoing problems with the written word. The written word is very clear. The main problem is Awi a says 1 Awi b says 2 Awi c says 3 Awi d says 1 Awi e says 2 Ive had aduit meeting were this has happened at the same table at the same time in the same room. Gerry ill give you this. At least you are consistent. You never place anything on this fourm that is of any value at all. Your like a little yap yap dog that just has a winny bark and never shuts the f#@& up. As ive said before i live this day in day out. One would think that if i had a problem it would have shown its self up by now. Pilots are consistent in that you cant tell them anything. Toot toot |
Originally Posted by Connedrod
(Post 9968137)
Gerry ill give you this.
At least you are consistent. You never place anything on this fourm that is of any value at all. Your like a little yap yap dog that just has a winny bark and never shuts the f#@& up. As ive said before i live this day in day out. One would think that if i had a problem it would have shown its self up by now. Pilots are consistent in that you cant tell them anything. Toot toot |
Originally Posted by LeadSled
(Post 9967872)
Progressive,
A comment about "servicing", so helpfully brought to our attention by CASA persons re. Schedule 8. There is no such thing as "servicing" in Australia, just maintenance. Doing a daily inspection is "maintenance". Checking the oil is "maintenance". Adding fuel is "maintenance", and so it goes on. AND --- all "maintenance" must be conducted to approved data. Many of us have argued, long and loud, that "servicing" should be as per the FAA, which is what you are quoting, and what we had in draft regulations (Part 91/135 and 43) in 1999. Thus, as the windscreen washing does not form part of the Manufacturer's Instruction for Continuing Airworthiness (not Servicing) there is no approved data. This is where the ratbag Australian approach to mindless "compliance" trumps common sense, commons sense being a very uncommon commodity in Australian aviation regulation. But, of course, CASA will not even accept that the AFM, by whatever name, forms part of the certifications of an aircraft, and regularly purports to direct operators to diverge greatly from POH/AFM procedures. If one or more manufacturer (it has always been in most FAR 25 aircraft MM) has now put said "approved data" in the MM of FAR 23 aircraft, as opposed to servicing, that is good, because it remove one item of harassment. Tootle Pip!! PS: Re. Jacking, way back I was only quoting the CASA "interpretation" as per the traveling roadshows, of Schedule 8, to point out the absurdities of CASA interpretations, not my reading of Schedule 8, but Conned Rod seems to have have ongoing problems with the written word. Actually servicing does form part of the Instructions for continued airworthiness for both FAR 23 and 25 - it is an entire chapter (usually chapter 2) of the Maintenance Manual and contains among other things windscreen cleaning procedures. A quick look through some of my outdated manuals reveals it has been in Cessna MM since at least 1960 and piper since 1964. Not sure how long it is since your read an MM. In addition as a lawyer I suggest you should bone up on CAR2A: For the purposes of paragraph (1)(a), the maintenance data are: (a) requirements in: (i) regulations 42U, 42W, 42X, 42Y, 42Z and 42ZA or in instruments made under those regulations; and (ii) directions (however described) made under an airworthiness directive or under regulation 25, 38 or 44; being requirements that specify how maintenance on aircraft, aircraft components or aircraft materials is to be carried out; and (b) specifications of how maintenance on an aircraft, aircraft component or aircraft material is to be carried out, in documents or designs approved under another provision of these Regulations; and (c) instructions, issued by the manufacturers of aircraft, aircraft components or aircraft materials, that specify how maintenance on the aircraft, components or materials is to be carried out; and (d) instructions, issued by the designers of modifications of aircraft or aircraft components, that specify how maintenance on the aircraft or components is to be carried out; and (e) any other instructions, approved by CASA under subregulation (4) for the purposes of this paragraph, relating to how maintenance on aircraft, aircraft components or aircraft materials is to be carried out. You would be hard pressed to argue that servicing or maintenance chapter of the POH/AFM and its associated supplements did not fit under the definition of "approved maintenance data" in (c) and (d). |
You would be hard pressed to argue that servicing or maintenance chapter of the POH/AFM and its associated supplements did not fit under the definition of "approved maintenance data" in (c) and (d) In a nutshell, re. "servicing",that is what counsel for CASA have argued, and in the same context in the AAT have differentiated between "servicing" in US paperwork, and the fact that, unlike the US, effectively everything that is done here, post manufacture, is "maintenance". In the same context, in US, maintenance is to acceptable data, plenty of guidance material to A&P, IA etc., whereas, as you can see from CAR 2A, here it is all "approved" data, the difference is not trivial. Then CASA turns handstands to try and define "approved", leaving lots of anomalies and "grey" areas, because there is not the US style latitude for on the spot flexibility. And there is the CASA "gotcha" enforcement mentality. As a former Head of CASA OLC said: "Pilots and engineers are just criminals who haven't been caught yet" ---- in my presence. That something like this leads to time and expense in the AAT and Federal Court (which obviously doesn't include the majority of cases where the poor sods on the receiving end, who surrender, cop the points, pay the fine and sign the Voluntary Enforceable Undertaking, because they have no other practical and/or affordable solution) is a great advertisement for the whole US approach, not just the FARs, but the whole FAA philosophical approach. Tootle pip!! PS: Just a further clarification re. the "windscreen wars", CASA persons argued that washing windscreens was not specifically listed in Schedule 8, notwithstanding #24. Re. jacking, again, it was not me arguing for ratbag interpretations of Schedule 8, I was only ever repeating what CASA persons have said at traveling roadshow "safety" presentation, where, re. Schedule 8, it was almost all in the negative, what you can't do, despite the document appearing to say otherwise. Don't shoot the messenger. |
There is an AWB defining servicing and maintenance and the difference thereof.
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Originally Posted by Eddie Dean
(Post 9969049)
There is an AWB defining servicing and maintenance and the difference thereof.
AWB 12-1 Issue 2 - Aircraft servicing and ground handling tasks AWB 12-1 Issue 2, 17 January 2002 Aircraft servicing and ground handling tasks Effectivity General information Purpose The purpose of this AWB is to provide information on the servicing tasks that may be carried out by, but not limited to, the pilot in command. Background Feedback to CASA shows some confusion may exist on the difference between servicing and maintenance. CAR 2 of the 1988 Regulations advises in part, that: 'Maintenance means…the doing of any work (including a modification or repair) on the aircraft that may affect the safety of the aircraft or cause the aircraft to become a danger to person or property…' 'Servicing…means preparing the aircraft for flight, and includes providing the aircraft with fuel and other fluids…but does not include any work that is maintenance.' Certification for the completion of servicing tasks is not required when preparing the aircraft for flight, unless specifically required as part of an approved system of maintenance. Certification is required when performing servicing tasks in conjunction with a maintenance activity. Advice If the aircraft is used for commercial operations, the operator is to ensure that flight crew are adequately trained to carry out servicing tasks. For private operations, if you do not know how to do these tasks, you should ask an LAME to show you. When replenishing fluids, you must use only those approved for the particular application. Servicing Tasks Refuelling and de-fuelling;Fuel system water drain checks;Replenishment of hydraulic fluid;Replenishment of engine oil;Toilet cleaning;Replenishment of engine coolant;Replenishment of water;Sanitize potable water;Adjustment of tyre pressures;Replenishment of de-icing fluid;Periodic lubrication of components, other than lubrication that is required for the accomplishment of scheduled maintenance, which does not require disassembly of the component, other than removal of non-structural items such as cover plates, cowlings and fairings eg: lubrication of door hinges;Aircraft internal and external cleaning, including windscreen cleaning;Disinfecting of the aircraft;Removal of ice and snow;Application of preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good maintenance practices;Checking aircraft battery electrolyte levels and topping up with distilled water but excluding wet cell nickel-cadmium batteries;Servicing tasks required by the aircraft flight manual or maintenance manual;Towing, parking and mooring including tasks to facilitate these functions eg: quick disconnect and re-connection of torque links; andReplacement or repair of signs and markings. Note: The servicing of liquid and gaseous oxygen systems is to be carried out only by an appropriately rated LAME. Last updated: 17 February 2016 |
Originally Posted by Eddie Dean
(Post 9969049)
There is an AWB defining servicing and maintenance and the difference thereof.
Exactly, and "servicing" is not maintenance, in fact it specifically precludes "maintenance", and I am not even going to attempt to list the contradictions, beyond S.3 of the Civil Aviation Act 1988. It is, in fact, another example of how screwed up our whole aviation legislative framework has become. I would be interested to know if "servicing" crops up in any regulation (except for a definition), as apposed to advisory material, such as an AWB --- I am not aware of it. Tootle pip!! Conned Rod, with your apparent delight in "discovering gotchas" you should apply for an AWI job. |
Originally Posted by LeadSled
(Post 9970135)
Eddie,
Exactly, and "servicing" is not maintenance, in fact it specifically precludes "maintenance", and I am not even going to attempt to list the contradictions. I would be interested to know if "servicing" crops up in any regulation, as apposed to advisory material, such as an AWB --- I am not aware of it. Tootle pip!! Conned Rod, with your apparent delight in "discovering gotchas" you should apply for an AWI job. No F/W i just know the law and how it applies to maintenance. Something that you clearly dont know as i have previously said. Its not my fault you given two ears and one mouth. Prehaps you should listen more and speak less. And stop treating me as some sort of fool which clearly i am not |
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