Stop scaremongering, kaz!

People don't want to know that even if the exemption is in force, all of this still applies to PVT GA aircraft: People don't want to know that the CASA guidance on ramp checks is therefore accurate. Pilots of PVT GA aircraft can be asked to produce paper or electronic copies of the checklist of the procedures from the flight check system established by the operator, and those pilots risk being considered in breach of 232(3) if those copies can't be produced. And if the pilot can't produce the copies, s/he is going to have difficulty in explaining how s/he can comply with 232(4).

But relax: The CASA guidance on ramp checks and CAR 232 read in light of the exemption don't mean what they say.

Far out. I'm developing a headache. If we need this much debate over something as simple as whether we should be carrying a checklist, no wonder we're all lost on the rest of it. When I did my training, up to PPL you didn't need a written checklist, doing it from memory was ok. As soon as I started doing my CPL training, we were required to use a written checklist. Back then it seemed simple. PVT = no checklist. Commercial = checklist. Am I simplifying it too much..? Was I taught wrong..?:confused:

I suppose it depends on whether rote learned checklists count as being "carried in the aircraft" and "located where they will be available instantly to" the PVT pilot. If the pilot's head is in the aircraft, and the pilot's head contains the checklists established by the operator and the pilot can recall them instantly, I don't see why that shouldn't be enough.

I suppose we'll find out CASA's opinion on the question, the next time they ramp check a PVT flight and ask for written or electronic copies of checklists in accordance with ramp check guidance, and the pilot says: "It's all in my head!"

Agreed, except for "Is it CASA approved?"

"INSTANTLY"....Who wrote this this stuff? How does anyone comply with "instantly"? Why would they?

Kaz

Of course it is. By virtue of having passed CAsA exams and being issued a licence; ergo we are approved!

End of story.:ugh::ugh::ugh:

Cheers
CB

Exactly Kaz! I stow all documents when doing aerobatics.

Talking with Colmar Brunton (for CASA's Safety Promotion communication research) so will include this topic.

Even I should read this more carefully. This exemption covers everyone NOT flying RPT

Exempts aircraft not RPT! That means EVERYTHING ELSE UNDER 5700kg.

???Makes you feel real important challenge responding away to yourself in your complex C182. This issue highlights how piss poor our flight training regime has become. Admittedly, until this thread surfaced I did not know we all operated light aircraft under a blanket exemption...from a law written to capture RPT.....but now I know and I am armed with that knowledge.

"As a condition on the exemption, an exempted operator will be required to describe the flight check system and publish it in the operator’s operations manual in accordance with regulation 215 or the aircraft’s flight manual."

Oz, does this mean everyone must have some sort of "Check System" in their Flight Manual??

As I read it, Catch 22 if your ramped..."May we see your flight manual"
Ah Ha!!..."Where is your flight check system"??

YES!! Your nicked you damned criminal, YES!! got another one!!
20 thousand penalty points, cough up you damned criminal!!

Sky is going to fall in😀😀😀😀😀😀😀😀😀😀😀
 

For god sake people, this is a storm in a tea cup.

I will be there, ask me 😀😀😀😀😀

Ducky, there are a Thousand other tea cups! That is the problem.

Taken individually, yes. It's a storm in a tea cup. But isn't it the case that virtually every other regulation has similar exemptions attached to it? This is why we are drowning! There is no point in studying the regulations; they prohibit everything not covered by plain vanilla Qantas RPT.

The problem we have here is structural - whole swathes of the Aviation industry for example RAA and Experimental, exist only by virtue of exemptions!

Then there are the emerging technologies - UAV's, ADS -B, EFB's advanced EFIS, traffic information systems. etc. etc. The benefits of which cannot be harvested by Australian aviators without exemptions.

"So what" You say? The problem, Ducky, is that the use of exemptions by the regulator maximises risk to the regulated because, by definition, the making of an exemption is at the pleasure of the regulator. This is because an exemption is not yours by right, subject to natural justice, procedural fairness and the entire set of Weberian bureaucratic procedural rules. Furthermore, the exemption can be revoked just as easily as it is created.

And what does the heightened level of risk mean for the regulated? Why it means jobs, investment and growth Ducky. Do I need to talk about risk premiums and rates of returns? The use of exemptions in Australia means that any aviation investment in what in other jurisdictions would be risk free is fraught with risk in Australia because it has to rely on exemptions to be operated let alone earn a sufficient return. Just ask Dick Smith. Ask the bloke who wanted to operate single pilot light jets.

In my case I have spent some $60,000 and invested hours of my time to try and build something which may fly only by virtue of exemptions. That doesn't worry me too much because I needed the therapy of just building it. If it all gets too hard to jump through more hoops, I will simply chainsaw the structure and sell the motor and avionics or shove the whole thing in a container and give it away to some African missionaries.

However think about the opportunity costs for the entire industry - how many investments are NOT made simply because the potential investor gets one whiff of how CASA is going to regulate him and just walks away? That is why our "storm in a teacup" matters.

Why bother, Oz?

Surely all you need to do is shout: THE EXEMPTION EXISTS.

:rolleyes:

Thorn bird, as someone pointed out a page ago.

To date, I have completed three special feature endorsments, I have passed my PPL and have had three AFRs...in all those assessments I have used a rote checklist. The aircraft I fly has a factory issued flight manual as well as a quick reference checklist...the manual is here...indicate...the quick ref check list is here...indicate. This is what you would say if you are DESCRIBING what you do and how your aircraft is equipped.

I have not studied the requirements for a kit built aircraft, I would understand there would have to be something on paper from the manufacturer as to the limitations placed on the aircraft by factory testing and design...same as section IV in all manuals. I would guess that anyone who builds their own aircraft would be creating a manual from derived data. The rote checklist would still stand.

Appols on the shouting bit. A protocol I still have issues with, to be sure. Wasn't shouting but certainly trying to highlight the important bits.

You did lead with your chin...

Anyway, for all of this complexity, we still don't know the answer to a simple question: Does CASA consider that rote-learned checklists, alone, can satisfy the requirements of CAR 232, to the extent that those requirements apply to PVT GA pilots?

We know that CAR 232 applies universally. It's just that the exemption exempts certain aircraft operators and their pilots from some (but not all) bits of CAR 232.

We also know that CASA's guidance on ramp checks for GA pilots says that CASA will ask for written or electronic checklists, with no distinction between GA PVT and GA AWK/Charter etc.

So going by all that, you'd be forgiven for believing that CASA doesn't consider rote-learned checklists to be sufficient.

It would be so easy for CASA to make a statement clarifying its approach, one way or the other.

I have absolute confidence in Jabba's integrity and I have no doubt that he's had a word in the ear of someone important who's made some representations about what CASA will and won't do at AusFly. But is that the proper way to give industry confidence about the regulator's approach?

Lead Balloon...I am in fierce agreement!

I see this all the time in other pastimes. I used to enjoy drag racing bigbore motorcycles....regretfully, so did a lot of outlaw motorcycle gangs. Many times I attended all bike meets that had big populations of gang members. It was only in Victoria that we were met with huge police presence to actively "discourage" participation by racers as well as spectators (cash source). Liberal interpretations on what described a road worthy vehicle. Best interpretation was...your spare tyre is not the same brand as your fitted tyres rewarded with a canary! Total BS!...but do you argue with a member of the Task Force?

...the guy with the tyres? He was the land owner! The task force defected the water truck which, effectively, cut off all the ablution blocks...public health? They tried everything to shut the show down...we never put on another one.

I see parallels in the actions of FOIs only at big gatherings of aircraft. Safety or discourage? I hope the SAAA has every and continued success with NRM. If allowed to develop, this could and will become our version of Osh!

As mentioned earlier, I don't have an AFM because my Auster never had one and is "exempt".

So does my AFM exemption exempt me from complying with the condition in the CAR 232 exemption or should this situation be better categorised as an "exception" to avoid confusion?


Kaz

The flight manual for my airplane is a document controlled by the manufacturer and approved by the FAA; I have no authority to publish a change to it.

My recollection of CASA's view of Auster's etc without an AFM is that the placards provide sufficient information.

kaz3g,
And you probably don't have an Operations Manual either (because they are not required for private operation), in which to "affix" the document(s) required by the footnote.

Remember, an AFM in not an Operations Manual.
Remember, a "flight check system" is not just a checklist.

Another example of a rather silly "one size fits all" rule to assist CASA micromanagement of aviation, and then not even being able to write an exemption that is clear and unambiguous, and actually applies to those operation that CASA seeks to exempt from a rule that shouldn't be in the first place.

But we all know we are not supposed to know and understand, because aviation law "is for lawyers and judges, for the safe conviction of pilots and engineers".
Tootle pip!!

On my reading of the exemption, the conditions apply only to commercial operations. But if that were intended, it could have been a stated a lot more clearly.

...and this is why we all love aviation in Australia. You need to be a talented linguist and a sharp lawyer to even agree that you are allowed to commit aviation.

I wonder if on the Professional Lawyers Rumour Network they have an aviation section?

A new piece of paperwork out of CASA that has the potential to cause some headaches: AWB 51-008.

(Extracts)

Effectivity
All aircraft that utilise tubular steel structure that is or forms part of the primary (or secondary) structure of the aircraft

Aircraft operators should ensure that the maintenance program for an aircraft constructed from welded tubular steel structure includes a requirement to periodically inspect all external and internal surfaces of the tubular structure. Any approved maintenance program which does not include a periodic inspection that will detect corrosion in the structure may be considered inadequate

(Emphasis mine)

If an appropriate inspection technique or NDT procedure is not available in the existing approved data for the applicable aircraft, such data may need to be developed by an NDT specialist in conjunction with a CASR 21M Delegate.

I wonder whether an engine mount is a primary or secondary structure? I would have thought so. Do aircraft have inspection techniques or NDT procedures in existing approved data that will detect corrosion on the internal surfaces of the engine mount?

Not to mention the effect on the presumably intended targets, where the fuselage etc. is welded steel tube.

How much weight does a "recommendation" in a AWB carry?

A story behind the AWB

Yes I understand the problem.

However I wonder whether it was necessary to declare potentially most/all current approved maintenance programs inadequate, and whether NDT procedures really need to be developed for each aircraft by a NDT specialist and CASR 21M Delegate.

Interesting... the one I was referring to is Issue 2. Issue 1 seems more reasonable.

Issue 1:

CASA recommends that if engineers or aircraft owners are concerned about
and / or suspect possible internal corrosion on tubular structures to consult with a specialised NDT person

Issue 2:

Aircraft operators should ensure that the maintenance program for an
aircraft constructed from welded tubular steel structure includes a
requirement to periodically inspect all external and internal surfaces of the
tubular structure. Any approved maintenance program which does not
include a periodic inspection that will detect corrosion in the structure may
be considered inadequate

"Periodic" is concerning....once every fifty years? Not!

To be sure, I am not familiar with the full suite of CARs for maintenance. There would have to be some sort of trigger to progress to NDT using X Ray examination. The case in question would indicate...corrosive environment, drains blocked or open to atmosphere, integrity of structure indicates weaken of joints..rather than a calendar date in service.

This will morph into X-ray inspection of engine mounts every Two years.

Just like the first blowie reminding us that summer is on the way, an AWB is a signal of an impending AD.

The dead giveaway is the buzzing in the background getting louder: you noted the difference in language between Issue 1 and Issue 2.

This is what happened with stainless steel terminated cables. The AWB morphed into an AD. Having demonstrated how well industry has learned to be helpless - the cable AD was met with little more than a shrug of resignation from the industry - CASA is moving on to primary and secondary tubular steel structures.

The way I read it, if there is not something already in the approved data for the particular aircraft, the operator is expected to pay a NDT specialist and CASR 21M Delegate to develop a program of periodic inspections.

Presumably they would set the intervals for inspection.

My gut feeling is CASA bit off more than they intended here. I doubt it was intended to include all aircraft, but I can't really see that you could claim the engine mount was a less important structure than e.g. the tail spring mount.

My response would be to buy a new engine mount

That doesn't solve the problem of an "inadequate" maintenance program.

CASA is incapable of building an "adequate" maintenance program. Comprehensive? Expensive? Both yes. "Adequate"? No.

For me, an internal wash with epoxy primer is adequate, coupled with a design that is fail safe or now " damage tolerant" so that blind Freddy can see he has a problem before bits fall off.

To put that another way; remind me how many corrosion related catastrophic failures of welded tubular structures have we had compared with all the other sources of accidents?

Sunny, all those tubular structures were clearly inadequate …..in 100% of fatal accidents the tubular segments all failed. They must be dangerous!!! :}

Jaba,
Careful, you might give some of the militants in CASA ideas.

Seriously, in this day and age, there are better things than linseed oil to fill tubes after welding. Having had some experience in such things, I would not go for a hard coating, but any one of a number of the coatings that are both a mechanical barrier to moisture, and have anti-corrosion properties.

Tootle pip!!

. Having had some experience in such things, I would not go for a hard coating, but any one of a number of the coatings that are both a mechanical barrier to moisture, and have anti-corrosion properties.

Omg. You are God. Knowledge of all. Master of all you must be god.

This is something I know a lot about. Even had this point in Court brought up.

How funny. Is there anything you don't know leadie.


Tootle pip!![/QUOTE]

yr write;


Are you stalking LeadSled?

nope not at all. He is very entertaining don't you think. I think he should head Casa be the PM and how about state prem as well. Head Easa may be FAA and maybe NZ Caa as well. Head the the law department and may be write the exams for aircraft maintenance. He could run a course on LOP and how to fill out a M/R as well.

But no I'm not.

Yr' wrong,
Why don't you tell us all what is, engineering wise, incorrect in my last post.
Fact is, you think you know about my background and experience, but by your posts, continually illustrate you have no idea.
Tootle pip!!

PS: As it happens, been there, done that.

Quite frankly your arse is jealous of what comes out of your mouth.

Your statement on linseed oil for a start. Do you know why that is used. So how many m/r have you issued oh that's right zero nil nada but your an expert on that. And btw I know lots about yourself. People only to happy to talk about your self. Blah blah.

So please tell us how you cam manufacture a window and install it. Still not done that.

yr' wrong,
Go back to the ATSB report on a previous post on this thread.
I stand by my statement that, in this day and age, corrosion prevention in tube frames has come a long way since linseed oil.
Tootle pip!!

PS: Has it ever occurred to your tiny mind that 4130 tube frames are not limited to aircraft, I built my first one before I was old enough to vote.