EASA money pit
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a grotty Christmas Eve here at home with a lousy cold.
I got a letter from the CAA yesterday about our a/c and the change to LAMP. I'm considering moving the date of the Annual from next July (silly time of year for an Annual) to this Feb coming and get the pain out of the way.
Cheers,
TheOddOne
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Perhaps I am missing something here but;
The owner has been responsible until not for ensuring that the paperwork was up to date, the mods and AD's, service letters and so forth were incorporated as required and that the required maintenance was completed when it was due not to mention that lifed components were changed at the end of their life, not after.
Many countries were very clear in this respect and required owners to be registered with the manufacturer for updates and to have or have the required access to the required manuals which had to be up to date etc.
When it came to the C of A renewal, the maintenance organisation and the owner completed the required paperwork exercise that renewing the C of A mostly was and hey presto the C of A was renewed.
Do we now have lots of owners who did not do the required paperwork, did not have the required information and simply blindly relied on others in the aviation world to look after them?
Do we also then have maintenance organisations who factored a certain amount of paperwork time into the C of A renewal costs who are now saying that they will now charge extra for the same paperwork exercie?
This EASA law is for Harmonisation if in order to harmonise with the standard you need to do lots of extra work then ask yourself why could this be if you were at the required standard?
I hope plenty of UK owners sell their aircraft. I would offer 50% of the value because it is becoming clear that there are lots of owners who did not maintain their paperwork etc to the required standard and if they are selling to avoid the cost, I am going to factor that into any offer.
Like I said, wait 3 to 5 years and see what difference there really is. Like JAR-FCL the answer will be none for bad but few for good.
Regards,
DFC
The owner has been responsible until not for ensuring that the paperwork was up to date, the mods and AD's, service letters and so forth were incorporated as required and that the required maintenance was completed when it was due not to mention that lifed components were changed at the end of their life, not after.
Many countries were very clear in this respect and required owners to be registered with the manufacturer for updates and to have or have the required access to the required manuals which had to be up to date etc.
When it came to the C of A renewal, the maintenance organisation and the owner completed the required paperwork exercise that renewing the C of A mostly was and hey presto the C of A was renewed.
Do we now have lots of owners who did not do the required paperwork, did not have the required information and simply blindly relied on others in the aviation world to look after them?
Do we also then have maintenance organisations who factored a certain amount of paperwork time into the C of A renewal costs who are now saying that they will now charge extra for the same paperwork exercie?
This EASA law is for Harmonisation if in order to harmonise with the standard you need to do lots of extra work then ask yourself why could this be if you were at the required standard?
I hope plenty of UK owners sell their aircraft. I would offer 50% of the value because it is becoming clear that there are lots of owners who did not maintain their paperwork etc to the required standard and if they are selling to avoid the cost, I am going to factor that into any offer.
Like I said, wait 3 to 5 years and see what difference there really is. Like JAR-FCL the answer will be none for bad but few for good.
Regards,
DFC
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DFC
Pardon my ignorance on this, but I think you are missing one of the key elements of the change.
We already keep the logbooks, arrange for maintenance to be done as and when and have an LAE signing off our 50 hour checks. Our annuals are donne by a reputable company a little away from our home base, where there is no maintenance facility.
As far as I am aware, the CAMO is the only organisation able to raise the paperwork to recommend the issue of the CofA and extend an ARC - you cannot do this yourself, unless you register, at some cost, with EASA.
You have 2 choices from next year - unless you operate a Permit or Annexe II aircraft. You can take the 'Controlled' route where you sign up with a CAMO and agree with them the limits of your maintenance freedom, or the 'Uncontrolled' route, where you pick and choose.
The CAA have already set the pricing regime to discourage the 'Uncontrolled Option' by making it considerably more expensive.
The problem we are already seeing is that perfectly acceptable maintenance organisations are shutting up shop. This reduces choice and puts us into the hands of cartels. In my area, 2 of the most popular organisations are closing their doors, and we will have to try to register with a very unpopular and overly-expensive EASA approved organisation instead - if, in fact they want to take us on, which is questionable.
As most of my friends left that facility because of their pricing and poor customer service, the thought of being forced back into their hands by EASA is one we find hard to bear.
As I said earlier, although not licenced engineers, we have, under supervision, doen much of our own work, but the plan, as stands will make life a lot more tricky after our next annual.
Pardon my ignorance on this, but I think you are missing one of the key elements of the change.
We already keep the logbooks, arrange for maintenance to be done as and when and have an LAE signing off our 50 hour checks. Our annuals are donne by a reputable company a little away from our home base, where there is no maintenance facility.
As far as I am aware, the CAMO is the only organisation able to raise the paperwork to recommend the issue of the CofA and extend an ARC - you cannot do this yourself, unless you register, at some cost, with EASA.
You have 2 choices from next year - unless you operate a Permit or Annexe II aircraft. You can take the 'Controlled' route where you sign up with a CAMO and agree with them the limits of your maintenance freedom, or the 'Uncontrolled' route, where you pick and choose.
The CAA have already set the pricing regime to discourage the 'Uncontrolled Option' by making it considerably more expensive.
The problem we are already seeing is that perfectly acceptable maintenance organisations are shutting up shop. This reduces choice and puts us into the hands of cartels. In my area, 2 of the most popular organisations are closing their doors, and we will have to try to register with a very unpopular and overly-expensive EASA approved organisation instead - if, in fact they want to take us on, which is questionable.
As most of my friends left that facility because of their pricing and poor customer service, the thought of being forced back into their hands by EASA is one we find hard to bear.
As I said earlier, although not licenced engineers, we have, under supervision, doen much of our own work, but the plan, as stands will make life a lot more tricky after our next annual.
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The CAA have already set the pricing regime to discourage the 'Uncontrolled Option' by making it considerably more expensive.
being forced back into their hands by EASA is one we find hard to bear.
Maintenance organisations that were up to scratch would have no problem with the new scheme but those old ones who either can't be bothered or are simply not capable of meting the basic international standards shut up shop. If that clears out a few cowboys then good.
One simply is left wondersing how can such supposed "capable" organisations have such trobble catching up with the rest of the world.
Now back to the paperwork. If your maintenance company completed the Annual and required paperwork exercise to renew your C of A previously and say that cost was X including work, parts, expendibles and paperwork then provided that they are capable of getting the required approvals then they can continue to complete your Annual and C of A paperwork.......then what has changed to justify an increase in costs......unless they were not doing it properly before!
Remember also that some European countries had annual C of A's for PT flights and 2 yearly for private.
Would you prefer to stick with the old system and have a C of A every year?..........would that be cheaper?
Regards,
DFC
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DFC
From your comments it would seem that you take the stance that the UK aircraft maintenance industry is providing poor service and is not keeping up with the new EASA requirements.
Quote:-
This EASA law is for Harmonisation if in order to harmonise with the standard you need to do lots of extra work then ask yourself why could this be if you were at the required standard?
The fact is that UK GA as a whole is the safest in europe and the number of accidents due to maintenance errors is almost nill.
The evidence is that UK based mantenance companys on the whole do a good job, yes there are one or two places that should not be in business but this is the same in any industry.
The problems with EASA part M are the extra paperwork that is required to do the job and the extra expence of the approvals required to do the work. The amount of maintenance "hands on" work on your aircraft won't change under EASA. What will change is the amount of paperwork that is required and the CAA charges for doing this paperwork.
You seem to think that this harmonisation is the UK stepping into line with Europe. It is not. It is an entirely new system for all Europe but as we know the Europeans are very good at sidestepping regulations that they don't like and most of the European states aviation authourity's are not required to recover costs from the industry.
So wile the CAA is diligently enforcing Part M on the UK and charging the "going rate" for it I fully expect the French to be ignoring the regulations and getting the services of the NAA paid for by the state.
Level european playing field? .......................I think not!
Quote:-
This EASA law is for Harmonisation if in order to harmonise with the standard you need to do lots of extra work then ask yourself why could this be if you were at the required standard?
The fact is that UK GA as a whole is the safest in europe and the number of accidents due to maintenance errors is almost nill.
The evidence is that UK based mantenance companys on the whole do a good job, yes there are one or two places that should not be in business but this is the same in any industry.
The problems with EASA part M are the extra paperwork that is required to do the job and the extra expence of the approvals required to do the work. The amount of maintenance "hands on" work on your aircraft won't change under EASA. What will change is the amount of paperwork that is required and the CAA charges for doing this paperwork.
You seem to think that this harmonisation is the UK stepping into line with Europe. It is not. It is an entirely new system for all Europe but as we know the Europeans are very good at sidestepping regulations that they don't like and most of the European states aviation authourity's are not required to recover costs from the industry.
So wile the CAA is diligently enforcing Part M on the UK and charging the "going rate" for it I fully expect the French to be ignoring the regulations and getting the services of the NAA paid for by the state.
Level european playing field? .......................I think not!
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DFC
As we were both posting messages at the same time perhaps I can give you an example of the extra paperwork that EASA is creating.
Under the UK system if you had lets say a DME fitted to your aircraft the avionic company would raise the MOD paperwork, send it to the CAA and they would decide if it was a Major or Minor modification.
In the case of a DME it would be a Minor MOD the charge would be in the order of £50, the DME would be fitted and that would be the end of it.
Each year the DME would be checked at the Annual check under the LAMS system.
The modification application now has to go to EASA and they then usualy send it to the CAA for implimentation, they then work in much the same way as before but with another layer of paperwork.
Now under EASA the aviomic company has to produce a document called Instructions for continued airworthiness This document runns to about seven pages for a simple DME instalation.
All this document tells you is what any avionic engineer should know and what is already mandated in LAMS or LAMP.
It is a pointless excercise but it writing this for each individual piece of extra equipment in an aircraft adds to the cost to the owner.
Under the UK system if you had lets say a DME fitted to your aircraft the avionic company would raise the MOD paperwork, send it to the CAA and they would decide if it was a Major or Minor modification.
In the case of a DME it would be a Minor MOD the charge would be in the order of £50, the DME would be fitted and that would be the end of it.
Each year the DME would be checked at the Annual check under the LAMS system.
The modification application now has to go to EASA and they then usualy send it to the CAA for implimentation, they then work in much the same way as before but with another layer of paperwork.
Now under EASA the aviomic company has to produce a document called Instructions for continued airworthiness This document runns to about seven pages for a simple DME instalation.
All this document tells you is what any avionic engineer should know and what is already mandated in LAMS or LAMP.
It is a pointless excercise but it writing this for each individual piece of extra equipment in an aircraft adds to the cost to the owner.
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For what GASIL is worth (not a lot usually), there is a mention on page 6/7 on Part M etc
http://www.caa.co.uk/docs/33/srg_gad_gasil4of2007.pdf
http://www.caa.co.uk/docs/33/srg_gad_gasil4of2007.pdf
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A and C,
Much of your complaint seems to be with the CAA. So why don't you title the thred CAA money pit...........because as you say, they are the ones charging the large sums of money and making a profit.
The instructions for continued airworthiness has been arround for decades. If you never came across it before then it says alot about the UK system.
Cessna when they used cessna branded radios decades ago inlcuded the info in the maintenance manuals as a matter of course.
If you wanted to put in a King set then you had to not only modify the flight manual but of course also the maintenance information etc etc.
Aircraft move round a bit and your aircraft with the new DME could be in Italy next week. No LAMS/P there and if you have not produced the required info for the DME then there is a hole in the maintenance information.
Once again I say...........nothing new there.
Regards,
DFC
Much of your complaint seems to be with the CAA. So why don't you title the thred CAA money pit...........because as you say, they are the ones charging the large sums of money and making a profit.
The instructions for continued airworthiness has been arround for decades. If you never came across it before then it says alot about the UK system.
Cessna when they used cessna branded radios decades ago inlcuded the info in the maintenance manuals as a matter of course.
If you wanted to put in a King set then you had to not only modify the flight manual but of course also the maintenance information etc etc.
Aircraft move round a bit and your aircraft with the new DME could be in Italy next week. No LAMS/P there and if you have not produced the required info for the DME then there is a hole in the maintenance information.
Once again I say...........nothing new there.
Regards,
DFC
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DFC
Yes you are correct information for continued airworthiness has always been avalable and it was expected that if any referance was required the engineer would just consult the manufactures manuals.
What is new is that for each aircraft the (in this case avionic) installer has to write for each individual aircraft and bit of kit installed a set of instructions to tell the engineers to look in the manufactures manuals.
If a maintenance company can't work out that they need a King manual to maintain and check a King DME they should not be in business. meanwile owners like you are going to have to pay to have this unnessesary paperwork produced.
As you say there is not a lot new in aircraft maintenance.................... Except the reams of paperwork that are required by EASA.
What is new is that for each aircraft the (in this case avionic) installer has to write for each individual aircraft and bit of kit installed a set of instructions to tell the engineers to look in the manufactures manuals.
If a maintenance company can't work out that they need a King manual to maintain and check a King DME they should not be in business. meanwile owners like you are going to have to pay to have this unnessesary paperwork produced.
As you say there is not a lot new in aircraft maintenance.................... Except the reams of paperwork that are required by EASA.
Last edited by A and C; 26th Dec 2007 at 22:17.
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The paperwork is necessary, and always has been necessary.
Like I said Cessna were doing ti back in the 50's. Don't know of your experience reaches back that far but you can still find the manuals.
It is more than simply the box maintenance. It is also about the instalation maintenance/ rectification............and as you know it can be different on every aircraft.
I would not touch an aircraft with a box of tricks fitted without all the required paperwork.
Now I can see why you say that many UK aircraft have lots of missing paperwork and why aircraft elsewhere do not have the same problem.
Again I say...........nothing new for me in all this. If engineering organisations are going to charge more for doing what they were doing (or should have been doing) all along then I can rightly claim that they are profiteering from the confusion surrounding the issue and in many cases, addid to that confusion probably for their own benifit.
The thred should be entitled CAA Money Pit.
Then you could indeed have a debate.
Regards,
DFC
Like I said Cessna were doing ti back in the 50's. Don't know of your experience reaches back that far but you can still find the manuals.
It is more than simply the box maintenance. It is also about the instalation maintenance/ rectification............and as you know it can be different on every aircraft.
I would not touch an aircraft with a box of tricks fitted without all the required paperwork.
Now I can see why you say that many UK aircraft have lots of missing paperwork and why aircraft elsewhere do not have the same problem.
Again I say...........nothing new for me in all this. If engineering organisations are going to charge more for doing what they were doing (or should have been doing) all along then I can rightly claim that they are profiteering from the confusion surrounding the issue and in many cases, addid to that confusion probably for their own benifit.
The thred should be entitled CAA Money Pit.
Then you could indeed have a debate.
Regards,
DFC
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DFC rubbish as usual!
I have just checked the maintenance manuals from three manufactures Piper, Robin and Cessna all have no more detail that contained in LAMS/LAMP.
The reqirement in each of these manuals is to check at intervals the avionic equipment to IAW the avionic manufactures requirments.
So why all of a sudden do we for each radio in each aircraft have to publish a 7 page document to tell us what to do in detail when it is contained in other manuals and referance to this data is contained in the manufactures maintenance program & LAMP/ LAMS?
DFC I don't think that you have yet seen a C.A.I. document and are in for a big shock at the next C of A renewal!
The reqirement in each of these manuals is to check at intervals the avionic equipment to IAW the avionic manufactures requirments.
So why all of a sudden do we for each radio in each aircraft have to publish a 7 page document to tell us what to do in detail when it is contained in other manuals and referance to this data is contained in the manufactures maintenance program & LAMP/ LAMS?
DFC I don't think that you have yet seen a C.A.I. document and are in for a big shock at the next C of A renewal!
Last edited by A and C; 27th Dec 2007 at 07:44.
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Easa = ???
I have been watching this thread for some time with great interest.
At a professional level, it pleases me to see that fellow Engineers are up to speed with the impending requirements as proposed.
At a personal level, it disheartens me as an owner/pilot to see how painful it will become to retain my aircraft on the G reg.
I am in the fortunate(?) position to have my own Part 145. However, this won't prevent the needless expenditure EASA are enforcing through the UK CAA. Nor will it ease the increase in totally wasteful paperwork. Neither of these two issues will make my own aircraft any safer. Continual in-depth inspections by experienced Engineers, both licenced and unlicenced, are the only way to catch something minor before it becomes more dramatic.
Unfortunately, the experienced guys are going to be busy dealing with more non-aircraft paper-shuffling tasks. Work the rest out for yourself. Hence the continual comment about this burden of paperwork not contributing positively in any way to aviation safety.
When I cornered my CAA surveyor earlier this year, I got him to give me the 'horses mouth' view regarding SubPart G CAMO's and ARC's. Sure enough, the CAA want three licenced guys doing what I have been doing for years. 'Who pays' says I. 'The customer will have to' says the CAA. I note that the CAA website makes no mention of this.
Although the CAA are carrying out the initial ARC issues, my surveyor stated that, with regard to the CAA carrying out ARC renewals, the Authority would make the situation financially untenable for the customer. This would assist forcing owners to stick with their present maintenance organisation so they remained in a 'controlled enviornment' even if the owner wasn't entirely comfortable with that organisation.
Therefore, moving from one organisation to another will be prohibitivly expensive, even if it is for the owners piece of mind, or worse still, to ensure the owner receives the quality of maintenance they rightly deserve. This expense is because the CAA will have to renew the ARC as the aircraft won't have been within a controlled enviornment for the previous twelve months. This is also the scenario if the owners present maintenance organisation call it a day.
It was also hinted that some retiring CAA surveyors were considering setting themselves up as CAMO's.
Add this latest grief to the same old line from the CAA 'we can't take anything away from you' which we Engineers know through experience, is codswallop. Remember when we had the ability to certify pressurised and unpressurised aircraft above 5700 Kg on your licence; issue Fitness for Flight to everything covered by your licence. This was only a couple of years ago.
Withen this short passage of time, the experienced Licenced Aircraft Maintenance Engineer is being fadded out to be replaced by an administrator with the new title Aircraft Maintenance Licence holder. Don't believe me? Ask your Engineer to show you his CAA and EASA licences. The old BCAR licence is an Aircraft Maintenance Engineers Licence. The new Part 66 licence is an Aircraft Maintenance Licence. We are slowly losing our identity, having our responsibilities redefined, and having our authorised capabilities reduced. Has any of this increased safety? I have my own views.
Acting as responsibly as possible, I have endevoured to keep my customers abreast of impending changes, attempting to be impartial without painting a black picture or overstating any issues. None of my customers have found fault with my explanations. They have, however, voiced considerable dismay with the CAA and EASA.
The two most common questions asked directly to me over the last year have not been 'how much to upgrade my avionics' or 'how much to replace my engine'. Instead, they have been 'how do I put my aircraft on the 'N' reg', or, 'I am going the PFA (LAA) route, what can I sell my aircraft for?'. There is also the growing realisation that G reg aircraft values may well dip in the near future as the market becomes potentially flooded with unwanted, overly-expensive to maintain aircraft.
As an A&P and PFA (LAA) inspector, it looks like I am going to be busy this coming year. And the best part? Very limited, if any, EASA input and paperwork. Might even be worth my while not renewing my Part 145 Approval. Hmm.
I posted a question on Pprune earlier. How many sub-5700Kg Part 145's have SubPart G CAMO approval. Have a look yourself to see what response I got.
There is a letter in the latest GA buyer from the Chief Engineer of Coulson Aviation Services (apologies for spelling). I suggest you all read it. It is another Engineer telling the GA community the reality of EASA. And it refers to the real and further decline in maintenance organisation numbers.
Over the next year, there are rumoured to be a number of established maintenance organisations who are going to call it a day and not renew their Approvals (not pay the CAA any more money). Having spoken to a number of the individuals involved, I know this to be substantiated and not just rumour.
The reasons given are consistant, and these are not my words:
Far too much paperwork for no perceived benifit in safety. Too much cost for insufficient return. Dissatisfaction with service from the Authority. Erosion of the professional licenced Engineers status. Small-minded EASA muscle-flexing against the FAA e.g. preventing the fitment of FAA PMA Approved parts in some instances; non-acceptance of American repaired or overhauled parts even with FAA Form 8130's attached.
DFC
It is commendable that you have taken an in-depth interest in your aircraft maintenance in the past. Long may your example continue. Unfortunately, if you don't gain CAMO approval yourself, you might find yourself frustrated when it comes to maintaining your oversight, as your CAMO will have the last word, not yourself. And you will have the pleasure and privelage of paying him/her to remind you of this, no matter what your view on this issue is. Welcome to the real world of EASA.
For all.
And remember, once the FAA have issued the C of A for an 'N' reg aircraft used for private use or training, they have no further involvement provided the aircraft is properly maintained. No FAA renewal fees. No organisation approval fees as your aircraft can be maintained by an A&P, and the modifications and Annual certified by an IA, thereby making maintenance cost effective and safe. Sensible FAA IR making flying safer. No wonder EASA wants to kick out the 'N' reg aircraft.
Enough for now, but remember, it is the eyes and experience of the licenced and unlicenced Engineers that spot and repair the defects and problems with your aircraft, not the attached six inch pile of paperwork.
P.S.
I have an unlicenced guy here who carries out the second part of the Independent Inspection...and he makes the tea.
Now, before you get on your high horses, he happens to have ten years experience within a 145 enviornment, and he has been properly briefed and Approved in accordance with Part M, and I trust him more than some of the Licenced idiots I have come across over the years.
camlobe
At a professional level, it pleases me to see that fellow Engineers are up to speed with the impending requirements as proposed.
At a personal level, it disheartens me as an owner/pilot to see how painful it will become to retain my aircraft on the G reg.
I am in the fortunate(?) position to have my own Part 145. However, this won't prevent the needless expenditure EASA are enforcing through the UK CAA. Nor will it ease the increase in totally wasteful paperwork. Neither of these two issues will make my own aircraft any safer. Continual in-depth inspections by experienced Engineers, both licenced and unlicenced, are the only way to catch something minor before it becomes more dramatic.
Unfortunately, the experienced guys are going to be busy dealing with more non-aircraft paper-shuffling tasks. Work the rest out for yourself. Hence the continual comment about this burden of paperwork not contributing positively in any way to aviation safety.
When I cornered my CAA surveyor earlier this year, I got him to give me the 'horses mouth' view regarding SubPart G CAMO's and ARC's. Sure enough, the CAA want three licenced guys doing what I have been doing for years. 'Who pays' says I. 'The customer will have to' says the CAA. I note that the CAA website makes no mention of this.
Although the CAA are carrying out the initial ARC issues, my surveyor stated that, with regard to the CAA carrying out ARC renewals, the Authority would make the situation financially untenable for the customer. This would assist forcing owners to stick with their present maintenance organisation so they remained in a 'controlled enviornment' even if the owner wasn't entirely comfortable with that organisation.
Therefore, moving from one organisation to another will be prohibitivly expensive, even if it is for the owners piece of mind, or worse still, to ensure the owner receives the quality of maintenance they rightly deserve. This expense is because the CAA will have to renew the ARC as the aircraft won't have been within a controlled enviornment for the previous twelve months. This is also the scenario if the owners present maintenance organisation call it a day.
It was also hinted that some retiring CAA surveyors were considering setting themselves up as CAMO's.
Add this latest grief to the same old line from the CAA 'we can't take anything away from you' which we Engineers know through experience, is codswallop. Remember when we had the ability to certify pressurised and unpressurised aircraft above 5700 Kg on your licence; issue Fitness for Flight to everything covered by your licence. This was only a couple of years ago.
Withen this short passage of time, the experienced Licenced Aircraft Maintenance Engineer is being fadded out to be replaced by an administrator with the new title Aircraft Maintenance Licence holder. Don't believe me? Ask your Engineer to show you his CAA and EASA licences. The old BCAR licence is an Aircraft Maintenance Engineers Licence. The new Part 66 licence is an Aircraft Maintenance Licence. We are slowly losing our identity, having our responsibilities redefined, and having our authorised capabilities reduced. Has any of this increased safety? I have my own views.
Acting as responsibly as possible, I have endevoured to keep my customers abreast of impending changes, attempting to be impartial without painting a black picture or overstating any issues. None of my customers have found fault with my explanations. They have, however, voiced considerable dismay with the CAA and EASA.
The two most common questions asked directly to me over the last year have not been 'how much to upgrade my avionics' or 'how much to replace my engine'. Instead, they have been 'how do I put my aircraft on the 'N' reg', or, 'I am going the PFA (LAA) route, what can I sell my aircraft for?'. There is also the growing realisation that G reg aircraft values may well dip in the near future as the market becomes potentially flooded with unwanted, overly-expensive to maintain aircraft.
As an A&P and PFA (LAA) inspector, it looks like I am going to be busy this coming year. And the best part? Very limited, if any, EASA input and paperwork. Might even be worth my while not renewing my Part 145 Approval. Hmm.
I posted a question on Pprune earlier. How many sub-5700Kg Part 145's have SubPart G CAMO approval. Have a look yourself to see what response I got.
There is a letter in the latest GA buyer from the Chief Engineer of Coulson Aviation Services (apologies for spelling). I suggest you all read it. It is another Engineer telling the GA community the reality of EASA. And it refers to the real and further decline in maintenance organisation numbers.
Over the next year, there are rumoured to be a number of established maintenance organisations who are going to call it a day and not renew their Approvals (not pay the CAA any more money). Having spoken to a number of the individuals involved, I know this to be substantiated and not just rumour.
The reasons given are consistant, and these are not my words:
Far too much paperwork for no perceived benifit in safety. Too much cost for insufficient return. Dissatisfaction with service from the Authority. Erosion of the professional licenced Engineers status. Small-minded EASA muscle-flexing against the FAA e.g. preventing the fitment of FAA PMA Approved parts in some instances; non-acceptance of American repaired or overhauled parts even with FAA Form 8130's attached.
DFC
It is commendable that you have taken an in-depth interest in your aircraft maintenance in the past. Long may your example continue. Unfortunately, if you don't gain CAMO approval yourself, you might find yourself frustrated when it comes to maintaining your oversight, as your CAMO will have the last word, not yourself. And you will have the pleasure and privelage of paying him/her to remind you of this, no matter what your view on this issue is. Welcome to the real world of EASA.
For all.
And remember, once the FAA have issued the C of A for an 'N' reg aircraft used for private use or training, they have no further involvement provided the aircraft is properly maintained. No FAA renewal fees. No organisation approval fees as your aircraft can be maintained by an A&P, and the modifications and Annual certified by an IA, thereby making maintenance cost effective and safe. Sensible FAA IR making flying safer. No wonder EASA wants to kick out the 'N' reg aircraft.
Enough for now, but remember, it is the eyes and experience of the licenced and unlicenced Engineers that spot and repair the defects and problems with your aircraft, not the attached six inch pile of paperwork.
P.S.
I have an unlicenced guy here who carries out the second part of the Independent Inspection...and he makes the tea.
Now, before you get on your high horses, he happens to have ten years experience within a 145 enviornment, and he has been properly briefed and Approved in accordance with Part M, and I trust him more than some of the Licenced idiots I have come across over the years.
camlobe
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Gentlemen, can I make a suggestion?
Find a nice cynical way to deal with this crap.
I have a business in electronics (30 years now) and we have been bombarded with all kinds of crap. BS5750, CE, ISO9000, ROHS, you name it.
A lot of it is sponsored not by Wonderful Europe but by fellow businessmen - people who make a living out of selling "consultancy" time, at anything up to £1000/day if EMC lab time is involved.
The electronics trade press carries constant righteous crap articles (written by journos who were failed engineers) about how such and such stupid reg will be enforced with strict penalties and how this is right and proper.
Many of their advertisers are electronics component distributors who nowadays are cardboard box shifters who add exactly zero value and just waste a couple of hours of your time while their stupid know-nothing sales rep takes you to lunch. Years ago, one company (Macro) employed mostly pretty women, so that was at least good fun (they knew nothing too but a good looking woman gets away with that every time), and obviously they were immensely successful, but eventually they had to stop the practice after some equal rights body set them up with bogus interview candidates. Anyway, these stupid distis are always desperately looking for ways to make the good old commodity-level components (which are cheap and plentiful) obsolete and forcing users to comply with new "standards" is always a good gravy train.
In the early 1990s a lot of people made loads of £ selling self adhesive "CE" stickers which would get stuck on everything.
Similarly, you get an "ROHS" (lead-free) rubber stamp which goes onto every carton. The Chinese print them onto everything as standard, even if it contains tampons.
Every time a new reg comes out, there is a mad panic as all the quality managers (invariably socially disfunctional little men who probably plane spot as their hobby) send out a load of forms for the company's suppliers to fill in, with questions like "do you have a system for segregating defective product" (yeah, Sir, actually, we deliberately mix up the crap with the good and send it all out of the door together
). The other day I had one such QM on the phone, British Rail no less, pointing out that the EN number in one of my data sheets became obsolete about 10 years ago and can I please re-issue another certificate referring to the new number. I told him politely to take his EN # and put it somewhere warm and dark; his business wasn't big enough to cover my time ordering the ISO documents and reading them.
Then we get export documents, 6 copies, with special wording certifying that the goods are made in the UK etc. The reality is that the box we send out could contain Chinese tampons and nobody will notice or care. The world is full of warehouses full of filing cabinets where this stuff is filed by endless streams of socially disfunctional little men.
Now we have ROHS, mandating lead-free solder and components and obsoleting vast swathes of equipment and designs, exposing soldered parts to much higher temperatures, and resulting in "non compliant" component stocks which have to go in the skip. Lots of people (Brits!) rubbing their hands. The more sensible firms just carry on and ignore it, or pretend to use one of the exemptions like "control and monitoring equipment".
Anyway....
What has happened in electronics is that you print up a form for everything, and sign it and rubber stamp it. It doesn't matter if it isn't really applicable; if it looks good, nobody cares.
For frequently repeated text you get a rubber stamp made. Very cheap.
Every label has "CE" on it. The regulars know it stands for "Chinese Export" and nobody cares.
If you want ISO9000, you get a consultant in for a few k, generate a load of forms, a Quality Manual (which nobody reads and which can be full of crap), and you generate a streamlined system under which you can continue making the same old product, the same way, and the paperwork is done efficiently. Everybody knows this now, which is why ISO9000 means nothing at all.
It's possible that people who work in aircraft maintenance are not as IT savvy or as literate as electronics engineers and thus find paperwork hard (certainly my barely legible maintenance records are a poor indictment of the UK education system) but if you get organised you can do it.
The 7 pages somebody mentioned are almost certainly pretty regular stuff and one could do some kind of standard form which you just duplicate / cross out bits and sign/stamp at the bottom.
Nobody is going to read it anyway; the vast majority of maintenance records get lost when the company goes bust years later. Only the most diligent owners ask for copies and they are welcome to the wads of paper.
I know a firm which does a fair number of TCAS installations; they have the paperwork for FAA and EASA all copied up and they just send it all off with the fees; minimal work really.
Rubber stamps are cheap and you can get a whole load made for standard wordings. Or use a PC, standard texts etc.
It's a cynical approach but when the regulatory authority is anally retentive what do they expect? You play their game, no less and absolutely no more.
Find a nice cynical way to deal with this crap.
I have a business in electronics (30 years now) and we have been bombarded with all kinds of crap. BS5750, CE, ISO9000, ROHS, you name it.
A lot of it is sponsored not by Wonderful Europe but by fellow businessmen - people who make a living out of selling "consultancy" time, at anything up to £1000/day if EMC lab time is involved.
The electronics trade press carries constant righteous crap articles (written by journos who were failed engineers) about how such and such stupid reg will be enforced with strict penalties and how this is right and proper.
Many of their advertisers are electronics component distributors who nowadays are cardboard box shifters who add exactly zero value and just waste a couple of hours of your time while their stupid know-nothing sales rep takes you to lunch. Years ago, one company (Macro) employed mostly pretty women, so that was at least good fun (they knew nothing too but a good looking woman gets away with that every time), and obviously they were immensely successful, but eventually they had to stop the practice after some equal rights body set them up with bogus interview candidates. Anyway, these stupid distis are always desperately looking for ways to make the good old commodity-level components (which are cheap and plentiful) obsolete and forcing users to comply with new "standards" is always a good gravy train.
In the early 1990s a lot of people made loads of £ selling self adhesive "CE" stickers which would get stuck on everything.
Similarly, you get an "ROHS" (lead-free) rubber stamp which goes onto every carton. The Chinese print them onto everything as standard, even if it contains tampons.
Every time a new reg comes out, there is a mad panic as all the quality managers (invariably socially disfunctional little men who probably plane spot as their hobby) send out a load of forms for the company's suppliers to fill in, with questions like "do you have a system for segregating defective product" (yeah, Sir, actually, we deliberately mix up the crap with the good and send it all out of the door together
). The other day I had one such QM on the phone, British Rail no less, pointing out that the EN number in one of my data sheets became obsolete about 10 years ago and can I please re-issue another certificate referring to the new number. I told him politely to take his EN # and put it somewhere warm and dark; his business wasn't big enough to cover my time ordering the ISO documents and reading them.Then we get export documents, 6 copies, with special wording certifying that the goods are made in the UK etc. The reality is that the box we send out could contain Chinese tampons and nobody will notice or care. The world is full of warehouses full of filing cabinets where this stuff is filed by endless streams of socially disfunctional little men.
Now we have ROHS, mandating lead-free solder and components and obsoleting vast swathes of equipment and designs, exposing soldered parts to much higher temperatures, and resulting in "non compliant" component stocks which have to go in the skip. Lots of people (Brits!) rubbing their hands. The more sensible firms just carry on and ignore it, or pretend to use one of the exemptions like "control and monitoring equipment".
Anyway....
What has happened in electronics is that you print up a form for everything, and sign it and rubber stamp it. It doesn't matter if it isn't really applicable; if it looks good, nobody cares.
For frequently repeated text you get a rubber stamp made. Very cheap.
Every label has "CE" on it. The regulars know it stands for "Chinese Export" and nobody cares.
If you want ISO9000, you get a consultant in for a few k, generate a load of forms, a Quality Manual (which nobody reads and which can be full of crap), and you generate a streamlined system under which you can continue making the same old product, the same way, and the paperwork is done efficiently. Everybody knows this now, which is why ISO9000 means nothing at all.
It's possible that people who work in aircraft maintenance are not as IT savvy or as literate as electronics engineers and thus find paperwork hard (certainly my barely legible maintenance records are a poor indictment of the UK education system) but if you get organised you can do it.
The 7 pages somebody mentioned are almost certainly pretty regular stuff and one could do some kind of standard form which you just duplicate / cross out bits and sign/stamp at the bottom.
Nobody is going to read it anyway; the vast majority of maintenance records get lost when the company goes bust years later. Only the most diligent owners ask for copies and they are welcome to the wads of paper.
I know a firm which does a fair number of TCAS installations; they have the paperwork for FAA and EASA all copied up and they just send it all off with the fees; minimal work really.
Rubber stamps are cheap and you can get a whole load made for standard wordings. Or use a PC, standard texts etc.
It's a cynical approach but when the regulatory authority is anally retentive what do they expect? You play their game, no less and absolutely no more.
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IO and Camlobe
Both your post made me chuckle. You tell it as it is.
It reminded me the last time I needed to get a new fuel pump.
No one had one in the UK, so I went direct to the manufacturer in the States.
How much is the pump? I asked
40 bucks, he said.
With the paperwork? I asked
Ah no, he said, with the paperwork that will be 180 bucks.
So what this difference? said I
We fit one to the Cheverolet, the other to your aircraft.
No, no what is the difference in the pumps, said I, you must test them to a higher standard?
Oh no, said he, same pump, same production line, no difference, except the paperwork that is.
Of course I had the one with the paperwork, because my engineer insisted.
Both your post made me chuckle. You tell it as it is.
It reminded me the last time I needed to get a new fuel pump.
No one had one in the UK, so I went direct to the manufacturer in the States.
How much is the pump? I asked
40 bucks, he said.
With the paperwork? I asked
Ah no, he said, with the paperwork that will be 180 bucks.
So what this difference? said I
We fit one to the Cheverolet, the other to your aircraft.
No, no what is the difference in the pumps, said I, you must test them to a higher standard?
Oh no, said he, same pump, same production line, no difference, except the paperwork that is.
Of course I had the one with the paperwork, because my engineer insisted.
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One point not lost on the more imaginative is that with any part which doesn't carry a serial number (and most small parts don't) you can use the paperwork which came with the previous one 
This enables you to purchase e.g. spark plugs from the USA. People like Aircraft Spruce try to con foreign customers (Brits, generally) out of $60 per item for an 8130-3 - a total ripoff. A lot of companies can't even supply an 8130-3. A lot can but only because they have an in-house inspector which can sign the piece of paper.
It's the same as the JAR145 scam - a JAR145 company can issue a JAR1 form for anything; they just need to look at it and fill in the form. I was quoted £800 extra for a certain engine part with a JAR1 form; the part is merely weight selected for dynamic balancing i.e. is not even touched, and the US company which does this charges about $100. $100 to £800 - not a bad margin and I suppose this kind of ripoff is what is needed to fund the JAR company approval. Another JAR145 company converted a $9000 prop (with an 8130-3 from Hartzell) to a £11500 prop (with a JAR-1 form from the JAR145 company).
Ultimately, this ripoff culture is all that safety regulation has achieved. To get the safety benefits (i.e. avoid counterfeit parts made of duff materials etc) all you need is a certificate of conformity!!! And they generally come free, in the form of a delivery note etc from the manufacturer...
You've got to laugh, because everybody up the supply chain has already fallen over backwards laughing at YOU.
This enables you to purchase e.g. spark plugs from the USA. People like Aircraft Spruce try to con foreign customers (Brits, generally) out of $60 per item for an 8130-3 - a total ripoff. A lot of companies can't even supply an 8130-3. A lot can but only because they have an in-house inspector which can sign the piece of paper.
It's the same as the JAR145 scam - a JAR145 company can issue a JAR1 form for anything; they just need to look at it and fill in the form. I was quoted £800 extra for a certain engine part with a JAR1 form; the part is merely weight selected for dynamic balancing i.e. is not even touched, and the US company which does this charges about $100. $100 to £800 - not a bad margin and I suppose this kind of ripoff is what is needed to fund the JAR company approval. Another JAR145 company converted a $9000 prop (with an 8130-3 from Hartzell) to a £11500 prop (with a JAR-1 form from the JAR145 company).
Ultimately, this ripoff culture is all that safety regulation has achieved. To get the safety benefits (i.e. avoid counterfeit parts made of duff materials etc) all you need is a certificate of conformity!!! And they generally come free, in the form of a delivery note etc from the manufacturer...
You've got to laugh, because everybody up the supply chain has already fallen over backwards laughing at YOU.
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IO540,
It's not as simple as that. The supplier will have a record of selling you an automotive part.
The only way to do as you say is to not record the fact that the pump is u/s and make no paperwork entries. Usually stands out a bit that the shiny new part must have been recently fitted...........check logbooks - no record, check credit card - automotive part ordered from US. Best paying in greenbacks when flouting the law.
-----------
Camlobe,
You simply make my position crystal clear - it is the CAA and not EASA that is causing much of the problems and uncertainty.
If the CAA is going to make the situation financially untenable for the customer then it is breaching the law and operating outside it's authority.
EASA should slap down these people ASAP and let everyone get on with what EASA intended and not how the CAA are trying to muck it up.
The problem with the title "engineer" is that people who simply pick up a screwdriver call themselves engineers these days in the UK.
---------
This whole thing reminds me of the UK family who paid thousands to replace their plumbing because the plumber told them their imperial pipework was not compatible with metric and only metric sizes are available these days.
You have to laugh and people who are stupid enough to believe such stories.
How many stupid owners are there who will either unnecessarly pay through the nose or unnecessarly give up?
Regards,
DFC
It's not as simple as that. The supplier will have a record of selling you an automotive part.
The only way to do as you say is to not record the fact that the pump is u/s and make no paperwork entries. Usually stands out a bit that the shiny new part must have been recently fitted...........check logbooks - no record, check credit card - automotive part ordered from US. Best paying in greenbacks when flouting the law.
-----------
Camlobe,
You simply make my position crystal clear - it is the CAA and not EASA that is causing much of the problems and uncertainty.
If the CAA is going to make the situation financially untenable for the customer then it is breaching the law and operating outside it's authority.
EASA should slap down these people ASAP and let everyone get on with what EASA intended and not how the CAA are trying to muck it up.
The problem with the title "engineer" is that people who simply pick up a screwdriver call themselves engineers these days in the UK.
---------
This whole thing reminds me of the UK family who paid thousands to replace their plumbing because the plumber told them their imperial pipework was not compatible with metric and only metric sizes are available these days.
You have to laugh and people who are stupid enough to believe such stories.
How many stupid owners are there who will either unnecessarly pay through the nose or unnecessarly give up?
Regards,
DFC
Try this one for size the details have been changed slightly to protect the innocent.
Pilot comes "in sorry boys but I've overtorqued the aircraft, my fault incorrect engine handling".
Engineers start to replace some very expensive hardware.
Part M gets involved and produces a process for returning the aircraft to service.
Part of this process is a check of the engine management system.
Engineers work through the process to humour the Part M, they know the cause of the problem ( he is sitting in the crewroom).
Bottom line is if no faults found replace the Fuel Control Unit, mega expensive. A test bed run will cost a few thousand with the recertification.
Engineers refuse to change the unit as they know that the cause was the "stick to seat interface".
The Part M insisted the unit was changed. Th engineers were forced to change it under protest.
Can't you just wait till that happens to you!!!!!!!!!!!!!!!!!!!!!!1
Pilot comes "in sorry boys but I've overtorqued the aircraft, my fault incorrect engine handling".
Engineers start to replace some very expensive hardware.
Part M gets involved and produces a process for returning the aircraft to service.
Part of this process is a check of the engine management system.
Engineers work through the process to humour the Part M, they know the cause of the problem ( he is sitting in the crewroom).
Bottom line is if no faults found replace the Fuel Control Unit, mega expensive. A test bed run will cost a few thousand with the recertification.
Engineers refuse to change the unit as they know that the cause was the "stick to seat interface".
The Part M insisted the unit was changed. Th engineers were forced to change it under protest.
Can't you just wait till that happens to you!!!!!!!!!!!!!!!!!!!!!!1
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I take it that by "Part M" you are referring toPart Manufacturer?
Can't see anywhere in European Law instructions for specific engine maintenance and repair. Lots of it in the Manufacturer's Maintenance, Overhaul and Repair manuals.
Good story.
Regards,
DFC
Can't see anywhere in European Law instructions for specific engine maintenance and repair. Lots of it in the Manufacturer's Maintenance, Overhaul and Repair manuals.
Good story.
Regards,
DFC