Part M - important news for owners/ operators
Gizajob
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Hopefully I can clarify slightly (we'll see in a paragraph's time!)...
As an owner/ operator, signing a contract with a Subpart G organisation means that THEY, not you become responsible for the aircraft's airworthiness - it's MA 201 (a) and specifically (e) to look at here. That's is in essence what you're paying for and why there is a contract.
Someone has to ensure the aircraft is maintained in accordance with a maintenance programme. In a 'controlled environment', the G organisation has that responsibility. As the owner/ operator, you can have a say about what goes into the programme but it is the job of the organisation managing the aircraft to ensure all items are covered and the work is done correctly (MA708b)
As an owner/ operator, you can instruct your managing company (the Subpart G organisation) to get maintenance performed anywhere and everywhere, so long as it's done by an appropriately approved organisation (i.e. Subpart F or Part 145) and released in accordance with Subpart H - that's MA 708b again.
There - clear as mud!
As an owner/ operator, signing a contract with a Subpart G organisation means that THEY, not you become responsible for the aircraft's airworthiness - it's MA 201 (a) and specifically (e) to look at here. That's is in essence what you're paying for and why there is a contract.
Someone has to ensure the aircraft is maintained in accordance with a maintenance programme. In a 'controlled environment', the G organisation has that responsibility. As the owner/ operator, you can have a say about what goes into the programme but it is the job of the organisation managing the aircraft to ensure all items are covered and the work is done correctly (MA708b)
As an owner/ operator, you can instruct your managing company (the Subpart G organisation) to get maintenance performed anywhere and everywhere, so long as it's done by an appropriately approved organisation (i.e. Subpart F or Part 145) and released in accordance with Subpart H - that's MA 708b again.
There - clear as mud!
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Nut Loose
Then what do we need a Part F for? Because as you say it will be someone else's responsibility to do the survey and eventually put their signature on it. This is precisely what an M3 organisation does today and will do for annex 2 aircraft.
Why not straight bananas whilst we're at it!
Then what do we need a Part F for? Because as you say it will be someone else's responsibility to do the survey and eventually put their signature on it. This is precisely what an M3 organisation does today and will do for annex 2 aircraft.
Why not straight bananas whilst we're at it!
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I'm used to surveyors having their own ways of interpreting things but this can you/can't you bit about being the CAM, ARS and signing the CRS takes it a bit far!
My surveyor came up on Wednesday for my (M3) audit etc and to discuss the 'future'.
Quoting from the CAA 'Acceptance of nominated Part M Airworthiness Review Certificate (ARC) signatories' guidance letter (March 08) that he supplied me with:
"M.A. Subpart G organisations with Part 145 / M.A. Subpart F approval, may nominate maintenance personnel from their Part 145 / M.A. Subpart F organisation as airworthiness review staff as long as they are not involved in the airworthiness management of the aircraft. These personnel should not have been involved in the release to service of that particular aircraft to avoid possible conflicts of interest."
My interpretation of the above is that you can't be the CAM, ARS and CRS issuer all on the same aircraft. Surely that goes against what others have been told and approved, or are those examples previously mentioned operating as 'one man very small organisations'? The next paparagraph says:
"In the case of a one-man organisation, since such a person has overall authority they can be nominated as airworthiness review staff."
My surveyor takes it that to qualify as a 'one man band' you can't be Sub Part F and therefore release aircraft on your licence a la M3.
Are you guys saying that you can have a 'one man Sub Part F' where one person can issue the CRS and ARC and be the CAM when Sub Part G and F are the same company?!
My surveyor came up on Wednesday for my (M3) audit etc and to discuss the 'future'.
Quoting from the CAA 'Acceptance of nominated Part M Airworthiness Review Certificate (ARC) signatories' guidance letter (March 08) that he supplied me with:
"M.A. Subpart G organisations with Part 145 / M.A. Subpart F approval, may nominate maintenance personnel from their Part 145 / M.A. Subpart F organisation as airworthiness review staff as long as they are not involved in the airworthiness management of the aircraft. These personnel should not have been involved in the release to service of that particular aircraft to avoid possible conflicts of interest."
My interpretation of the above is that you can't be the CAM, ARS and CRS issuer all on the same aircraft. Surely that goes against what others have been told and approved, or are those examples previously mentioned operating as 'one man very small organisations'? The next paparagraph says:
"In the case of a one-man organisation, since such a person has overall authority they can be nominated as airworthiness review staff."
My surveyor takes it that to qualify as a 'one man band' you can't be Sub Part F and therefore release aircraft on your licence a la M3.
Are you guys saying that you can have a 'one man Sub Part F' where one person can issue the CRS and ARC and be the CAM when Sub Part G and F are the same company?!
Gizajob
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Are you guys saying that you can have a 'one man Sub Part F' where one person can issue the CRS and ARC and be the CAM when Sub Part G and F are the same company?!
Your surveyor may be correct in saying 'one man' organisations would have trouble attaining Subpart F, due to all the other requirements (facilities, management structure etc etc) but there is nothing to prevent it if all requirements are met.
Be aware that this legislation is new for everyone - including the CAA. Knowledge levels vary among surveyors and it's always worth pressing for written justification (via the AMC or Part M itself) if you have a query.
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Hi thanks for that, I've emailed my surveyor to add to his confusion with what has been said here!
It was more of the 'one man band' is required if you want to do CAM, ARC and CRS because one person can't do all three under Sub Part F - that's what his view was!
We intend to go for Sub Part F (as well as G and I) and are fortunate to have all the other boxes ticked (ie facilities etc).
Ho hum, back to the CAME writing - surveyor says a new 'Anybody's CAME' will be out 'at some time' but to use the old one because no one knows when it will appear. He hadn't even seen the letter we were sent last week by the CAA about the 05 Jan 09 Sub Part G extension.
As you say, the CAA don't know all the facts either which makes it a tad difficult for them to pass on accurate info to the industry.
It was more of the 'one man band' is required if you want to do CAM, ARC and CRS because one person can't do all three under Sub Part F - that's what his view was!
We intend to go for Sub Part F (as well as G and I) and are fortunate to have all the other boxes ticked (ie facilities etc).
Ho hum, back to the CAME writing - surveyor says a new 'Anybody's CAME' will be out 'at some time' but to use the old one because no one knows when it will appear. He hadn't even seen the letter we were sent last week by the CAA about the 05 Jan 09 Sub Part G extension.
As you say, the CAA don't know all the facts either which makes it a tad difficult for them to pass on accurate info to the industry.
I sympathise Smarthawke - makes a hard job even harder eh? Sent you a PM btw.
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Think IO-540 hit the nail on the head here:
My experience is that the happiest owners who keep their planes in the best condition are ones who have the freedom to pick and choose who does what (and yes a disproportionate % of those are N-reg because doing exactly that is easier on the N-reg). I am one of these but it took a while to suss things out.
Large chunks of the maintenance scene are nothing short of a disaster, but if you are not careful you will end up over the barrel belonging to one of these companies.
I just visited a Sub Part F/G firm who I wanted to talk to about keeping my C180 G-Reg machine on the G-Reg post EASA rules in Sept. They showed me a C150 they had taken in for an Annual - so far they spent 900 HOURS on it... I know it was in bad order, but thats twice what the AC is worth. I see the N reg being the lesser of two evils - come what may in Sept..... The only thing thats certain about the pending EASA rules is that maintenance organisations will ride you Ten Stone Eight!
My experience is that the happiest owners who keep their planes in the best condition are ones who have the freedom to pick and choose who does what (and yes a disproportionate % of those are N-reg because doing exactly that is easier on the N-reg). I am one of these but it took a while to suss things out.
Large chunks of the maintenance scene are nothing short of a disaster, but if you are not careful you will end up over the barrel belonging to one of these companies.
I just visited a Sub Part F/G firm who I wanted to talk to about keeping my C180 G-Reg machine on the G-Reg post EASA rules in Sept. They showed me a C150 they had taken in for an Annual - so far they spent 900 HOURS on it... I know it was in bad order, but thats twice what the AC is worth. I see the N reg being the lesser of two evils - come what may in Sept..... The only thing thats certain about the pending EASA rules is that maintenance organisations will ride you Ten Stone Eight!
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I have much sympathy for Irish Seaplanes point of view but has he considered what the maintenance companies think of part M?
Most of us just want to get on with the day to day job of maintaining customers aircraft, all that this paperwork is doing is getting in the way! It is taking senior staff away from the hangar floor to produce tons of paperwork that has very little effect on flight safety. These staff would be much better employed inspecting aircraft and directly supervising the work.
I can't help thinking that part M will push up prices and reduce the safety standards because the paperwork will distract people from the important job of inspection.
I would be most interested to see what is happening in France over all of this and would look with interest at the way pat M is administered.
Most of us just want to get on with the day to day job of maintaining customers aircraft, all that this paperwork is doing is getting in the way! It is taking senior staff away from the hangar floor to produce tons of paperwork that has very little effect on flight safety. These staff would be much better employed inspecting aircraft and directly supervising the work.
I can't help thinking that part M will push up prices and reduce the safety standards because the paperwork will distract people from the important job of inspection.
I would be most interested to see what is happening in France over all of this and would look with interest at the way pat M is administered.
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I know this particular thread only represents a small sample of engineers and owners but I get the impression that most people don't want all the extra bureaucracy associated with Part M. I always believed that the CAA's job was to look after the interest of us poor punters, much as they do for airline travellers; are they listening?
Gizajob
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I think you're right jxk, but CAA is ultimately a government agency and even the government's hands are tied. The consultation has been done, the laws written and all but implemented. The only way to change things now is through long and arduous lobbying at European level, with any significant change taking years to show as a benefit at our level. Wish I could be more cheerful about it but I think we just have to get on with what we've got and try to make the best of it...
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The only way to change things now is through long and arduous lobbying at European level
French
Italians
Spanish
and in fact probably everybody south of the Alps
Only the UK, and perhaps Germany, will interpret strictly.
Yes you're quite right IO. Chaos rules!
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Ten years of maintaining my French registered / UK based, Robin make me think that "Creative Interpretation of the Rules" has a lot going for it.
Brits however sometimes seem more concerned with following the letter of regulations, rather than achieving the intentions behind them.
Perhaps an appreciation of what EASA is trying to do would make the convoluted rules more understandable. Certainly under the French system I have been able to do all necessary work on my aeroplane to achieve safety, and then adjust the paperwork to fit. That was under the existing French system , and I anticipate very little difference with part M.
Indeed under part M it seems I can be my own CAMO and do much of the hands on servicing under Appendix VIII, and issue a CRS. What I have been doing for the past 10 years is about to become fully legit.
Brits however sometimes seem more concerned with following the letter of regulations, rather than achieving the intentions behind them.
Perhaps an appreciation of what EASA is trying to do would make the convoluted rules more understandable. Certainly under the French system I have been able to do all necessary work on my aeroplane to achieve safety, and then adjust the paperwork to fit. That was under the existing French system , and I anticipate very little difference with part M.
Indeed under part M it seems I can be my own CAMO and do much of the hands on servicing under Appendix VIII, and issue a CRS. What I have been doing for the past 10 years is about to become fully legit.
Last edited by vee-tail-1; 23rd Aug 2008 at 21:35.
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This could mean large numbers of people re-registering in other EASA countries.
With JAA licenses, the registration does not matter.
I know some people do it already but I have never found a clear list of the benefits of being on say a D-reg.
The only thing is the letter of ANO article 140 which bans any aerial work in a foreign reg plane, and while the DfT will give you permission to receive training in one, and some other stuff, this is a hassle. It incidentally also bans the traditional PPL Cost Sharing scheme - the passengers may not contribute a single penny towards the flight. I vaguely recall somebody having got a letter from the DfT saying Art 140 does not apply to EU-reg but have never seen a reference.
If there is an enforced move from N-reg to EU-reg, anybody doing that will naturally shop around for the most appropriate nationality. I should think some new EU members e.g. Romania might provide interesting options. There will be thousands of pilots in Europe doing this - if it happens.
With JAA licenses, the registration does not matter.
I know some people do it already but I have never found a clear list of the benefits of being on say a D-reg.
The only thing is the letter of ANO article 140 which bans any aerial work in a foreign reg plane, and while the DfT will give you permission to receive training in one, and some other stuff, this is a hassle. It incidentally also bans the traditional PPL Cost Sharing scheme - the passengers may not contribute a single penny towards the flight. I vaguely recall somebody having got a letter from the DfT saying Art 140 does not apply to EU-reg but have never seen a reference.
If there is an enforced move from N-reg to EU-reg, anybody doing that will naturally shop around for the most appropriate nationality. I should think some new EU members e.g. Romania might provide interesting options. There will be thousands of pilots in Europe doing this - if it happens.
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IO540
I certainly would'nt recommend the G register! It seemed logical to transfer from French registration when I bought my Robin. But the ludicrous requirements of CAA surveyors became almost comical before I pulled the plug and abandoned the whole exercise. For example: They have a generic requirement for a starter warning light. So I duly reactivated a redundant warning light circuit to provide it. But this was considered to be a mod and required full investigation and approval by EASA. Next they considered that my then recent top overhaul was not properly documented and needed to be investigated by a licensed engineer. When they started talking about removing some of the fabric wing covering to investigate the wood structure ..I told them to get lost! Like I say some Brits love rules rather than results
.
I certainly would'nt recommend the G register! It seemed logical to transfer from French registration when I bought my Robin. But the ludicrous requirements of CAA surveyors became almost comical before I pulled the plug and abandoned the whole exercise. For example: They have a generic requirement for a starter warning light. So I duly reactivated a redundant warning light circuit to provide it. But this was considered to be a mod and required full investigation and approval by EASA. Next they considered that my then recent top overhaul was not properly documented and needed to be investigated by a licensed engineer. When they started talking about removing some of the fabric wing covering to investigate the wood structure ..I told them to get lost! Like I say some Brits love rules rather than results
.
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When my TB20 was new in 2002 and going onto the G-reg, the CAA inspector
- insisted on EXIT stickers on the doors
- insisted on a "VFR ONLY" placard on the IFR GPS (which already had a BRNAV certification from the DGAC so good for IFR enroute)
- insisted that the IFR features in the GPS were disabled
- insisted on an INOP placard on the prop TKS de-ice operating switch
Great stuff, which really enhanced my safety.
Then, when 3-4 years later the CAA wonders why there is so little participation in their GPS approach trials, they are suprised that so few had the required certified equipment. Today, only N-reg owners, and a miniscule handful of G-reg owners (probably under 10 in all of the UK) have approach certified GPSs.
Britain has a particular tendency to generate large numbers of little men who love implementing regulations. In my business (electronics) I come across them too, constantly lobbying the Govt and the EU for new regs on which they can "offer consultancy services".
The more southern countries also love paperwork (Greece and Italy being really bad) but they ignore the regs they don't like, just as long as there is enough paperwork left over to create the expected jobs. The content of the paperwork itself is not important, so long as somebody gets paid for it.
- insisted on EXIT stickers on the doors
- insisted on a "VFR ONLY" placard on the IFR GPS (which already had a BRNAV certification from the DGAC so good for IFR enroute)
- insisted that the IFR features in the GPS were disabled
- insisted on an INOP placard on the prop TKS de-ice operating switch
Great stuff, which really enhanced my safety.
Then, when 3-4 years later the CAA wonders why there is so little participation in their GPS approach trials, they are suprised that so few had the required certified equipment. Today, only N-reg owners, and a miniscule handful of G-reg owners (probably under 10 in all of the UK) have approach certified GPSs.
Britain has a particular tendency to generate large numbers of little men who love implementing regulations. In my business (electronics) I come across them too, constantly lobbying the Govt and the EU for new regs on which they can "offer consultancy services".
The more southern countries also love paperwork (Greece and Italy being really bad) but they ignore the regs they don't like, just as long as there is enough paperwork left over to create the expected jobs. The content of the paperwork itself is not important, so long as somebody gets paid for it.
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Not fit or purpose
I remember Gwyneth Dunwoody (now no longer with us) chairing a parliamentary committee regarding EASA - the committee found EASA 'not fit for purpose'. Does anyone know what has happened since?
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It makes no odds - they also gave the CAA a sort of clean bill of health and blamed all the rest on the EU. As it is part of the EU gravy train, there is nothing the HoC can do about it.
Oh, and since the review of the CAA by the Transport Committee, there has been mega-silence from the CAA despite their promises to engage with us regularly. We haven't had the long-promised second GA conference yet
Oh, and since the review of the CAA by the Transport Committee, there has been mega-silence from the CAA despite their promises to engage with us regularly. We haven't had the long-promised second GA conference yet