Part M - CAMO - etc

[smarthawke]

Re ARC subsequent issues, it comes down to how much a new CAMO trusts the previous CAMO. The buck, as usual, stops with the last signature. Personally, if an unfamiliar aircraft turned up on my doorstep for an ARC issue, no matter how many ARCs it has had before, I would ensure that ALL mandatory requeirements had been complied regardless of what another engineer said.

Now of course if all engineers were created equal then it wouldn't be a problem, but....

The CAA may state what the legal case is and what they require but they aren't going to have their licences pulled for someones elses failings.

As for the interpretation of allowing items to continue 'on condition' where the Maintenance Manual states otherwise, I know what my CAA surveyor would say to that.

[alphamikeecho]

Searbelts

I do have a concern about these!

Having purchased an aircraft which used to be looked after by a reputable maintenance company last year. The aircraft is nearly 30 years old, the seatbelts were the original ones despite the fact the manual says they are supposed to be lifed at 10 years. Fair enough you might say to run on condition. Except the pax seatbelt was attached to the airframe by a tiewrap, and when the belts were removed (to be replaced) the stitching fell apart.

Now maybe the owners had a say in not replacing them at the last check, but someone released that aircraft to service.

Luckily we didn't have to test the old belts in anger. Now we have fitted ones that aren't lifed.

ame

[robin]

Personally my issue is a company that has maintained the aircraft for over 10 years now finding faults.

What were we paying for over the past 10 years before Part M and are we entitled to cash-back.....

[IO540]

I would ensure that ALL mandatory requeirements had been complied regardless of what another engineer said.

Surely, maintenance has to be done on trust.

One company is entitled to assume the previous one did the job right.

Otherwise, you would end up paying for an Export CofA Annual every year, which is stupid.

[smarthawke]

I totally agree IO - if it were a perfect world. Unfortunately, it isn't a perfect world and as I said - he (or she) who signs last will be held responsible for the aircraft's airworthiness as a whole regardless of what has been done before. This means that, as far as you can, you ensure everything has actually been done that has said to be done.

The ultimate result of this is the threat of losing one's income due to someone else's error when the authorities come investigating. And I like my job, it saves me getting a real one....

[IO540]

who signs last will be held responsible for the aircraft's airworthiness as a whole regardless of what has been done before

Do you have a reference for that? It is very much against natural justice and would never stand up in Court.

Take two scenarios I can think of, where I turn up at your firm for an Annual. Current TT is 800hrs; last Annual was done (different company) at 650hrs.

(1) My mags are at 800hrs, OH reqd at 500hrs, logbook entry exists to say it was done at 500hrs

(2) My mags are at 800hrs, OH reqd at 500hrs, no logbook entries on the subject

IMHO, in case (1) you are in the clear because you are 100% entitled to assume that the logbook entry is not a forgery. Otherwise, please provide a reference to the contrary, and actual case law. This cannot be legal because it would make you liable for the previous firm's document forgery.

In case (2), it is not so clear, is it? I'd like to see the legal guidance on this, if there is any. You are entitled to assume that last company did the job right, no? If not, that opens a huge can of worms because basically every plane going for an Annual with incomplete past records will need a full Export CofA. But I can see a directive to this effect standing up legally - despite being practically unworkable because of how much detail do you go into? This would be dealt with with professional liability insurance; accountants and solicitors have the same problem (conveyancing is one example where you can be sued for previous peoples' stuff).

I have had situation (2) on my plane (more accurately, some logbook entry did not make sense because it showed some work was done but the # of hours was not related to any actual SB or whatever) and I had it re-done immediately. But hey this is my own plane, I know where it's been, and I maintain it with money no object (especially the single shaft mags ).

[smarthawke]

IO, I think you are perhaps taking my words too literally.

An ARC issue requires that all the past continuing airworthiness has been carried out etc etc and the aircraft is fine fettle. At the first ARC a company would go 'back to birth' - as far as one can. At the CAA Subpart G course I attended, the CAA agreed that it wouldn't always be possible to have all the log books, workpacks etc on hand to check this. In the case of GA machines there are rarely ADs etc carried out that can't be checked for compliance at a later date. At the next ARC, you only have to review work carried out/required to be carried out since the previous ARC.

If I hadn't seen an aircraft before and was issuing an ARC on it for the first time, I would want to satisfy myself that all ADs etc that were required to be carried out, had indeed been carried out. This may be accomplished by signatures in log books accompanied with Form 1s (for instance in the case of mag overhaul), signatures in the log book pink pages etc. No engineer is likely to accept the word of an owner that the mags had been overhauled without documented proof. It's easy enough to check with the company that overhauled the mags that the work had been carried out.

I'm not sure what the problem is with this anyway. How I choose to do my job doesn't affect the owner - we charge for a 'Star Annual' irrespective of the man hours and expense I put into the paperwork side and the amount of time I put into satisfying myself that all is well is up to me.

I'm not sure why the referral to the Export CofA is about - that too is only as good as the person carrying out the inspection just the came as any Annual or Star Annual.

We took on a Mooney for a 6 month/50hr check and there was more camshaft in the oil filter than in the rest of the engine. The aircraft had flown 1100 hours in 18 years, sitting around a lot outside, then flew a 100 hours in a year, Annual carried out and the aircraft sold. 6 months and 13 hours later it came to us for the check. It turned out that the new owner had bought the aircraft ( and flown the 13 flying hours) from a CAA licensed engineer who had rebuilt the aircraft following an EFATO (water in the fuel from sitting around outside, unflown) and a landing roll through a substantial wooden fence which (documented by photographic evidence) trashed both wings and bent one blade of the prop. The wings were rebuilt (no major problems apparent) but the engine hadn't been out for a shockload. The only documented evidence of engine work was the removal of 2 cylinders for a visual camshaft inspection. The previous owner claimed the new owner had abused the engine in its 13 hours of flying and had caused the canshaft failure. Subsequently, he did contribute to the engine overhaul costs...

My point? Not all engineers work to the same standards, that is a fact of all walks of life. What I do is ensure that, as far as is possible, aircraft leave us with everything correct - mechanical and paperwork-wise.

[flyingfemme]

I don't deal with the CAA so please forgive my ignorance........

Going "back to birth" is not really compatible with "as far as one can" - one or the other. There are many, older aircraft around that don't have all logs from new. It was often the case, with imports, that foreign logbooks were spirited off never to be seen again. How far does the discretion of the ARC issuer stretch?

Presumably the paperwork from the original ARC issuance becomes part of the paperwork history belonging to the aircraft (the owner paid for it after all) - so subsequent ARC processes can simply refer back to a list of SBs, ADs and modifications in an easy-to-check format?

[A and C]

Aircraft tech records

I feel that some extream positions are being taken on this thread, a CAMO has to ensure as far as is practicable that all the maintenance tasks are compleated and time life items are all in date.

Some form of documentry evidence is required, If the last CAMO had put an entry in the log book that a Mag had a 500 hour check at XXXX hours then that is good enough for me and I would program the next Mag inspection at XXXX hours +500.

The problems come when the mainteance records are poor and incomplete, the fact is that you cant trust some owners to tell the truth when they think it might save them some money, I have had one owner lie to me to try to avoid having to pay for a major safety related AD on both the mags on his aircraft.

If i had taken the guy at his word and the aircraft was involved in a major accident what would have been the outcome for me?

Recent events indicate long and expensive court action with the dependents of the pilot/passengers seeking damages and that is likely to be the best outcome, if someone decides that this is criminal negilgence then a manslaugter charge would be made.

So for taking the owners word it is not unrealistic to say that I could be jailed and pennyless.

So that Bose-x is why I am very carefull about what I put my name to because if people like you die in a crash I expect your dependents to be very quick to court to seek compensation................... this is why Engineers are very keen to keep you alive despite your opinion that we are all money grabbing pirates.

[jxk]

A and C
Good answer. Also image that it was a 747 and the engineer just took a cursory glance around and said that looks OK. Would bose_x be happy with this situation? It looks as if bose has had some pretty sloppy people taking care of his maintenance in the past and now its catching up with him..

[S-Works]

It looks as if bose has had some pretty sloppy people taking care of his maintenance in the past and now its catching up with him.

.

My god, where have I made any complaint about the standard of my past maintenance? That is just a plain cheecky remark and not founded on anything that I have said in this thread.

My aircraft has spent it's whole life being maintained to the highest standard and I have no complaints what so ever about it.

I am referring to my experiences of having to find a Part M company as my existing company have not got Part M. I recounting the story of what I have been told by a number of part M companies, a lot of which seems to be less than factual.

Some of you really should read what has been said before opening your big gobs and making comment on half read stuff.

this is why Engineers are very keen to keep you alive despite your opinion that we are all money grabbing pirates.

I have never said this. In fact many times I have stood up for engineers in the past when others have accused them of being pirates.

If you read my very comments in this thread you will see that I want my engineers to be trusted to make the decisions that they are trained and experienced for, not having some bureaucrat doing some arse covering exercise and making stuff that was at engineers discretion in the past compulsory.

I have always left the decisions on what needs to be done to my engineers and as a result the aircraft has operated 100% perfectly for it's entire life in my possession. I can assure you that my maintenance records are 100% accurate, maintained by my previous engineers to the highest standards and I hope that my new engineers will continue in the same vein.

Sometimes some of you lot are cheeky judgemental bastards who only looking for a fight half read stuff. Quick to fire a response with half the facts.

[jxk]

bose-x
I quit you win.

[IO540]

Smarthawke

I think you are perhaps taking my words too literally.

If you don't write enough detail, that will sometimes happen

You are however talking about checking if an AD has been carried out. I was talking about more general stuff like mag OH at 500hrs which didn't get written up in the logbook at the previous Annual (done by a different company). The first must be recorded and if not you have to physically inspect and unless it has evidently been done you have to [re]-do it; the 2nd is a bit of a grey area - IMHO - and could be used as a money earning opportunity because there is not one plane flying whose logbooks are perfect. Not one plane landing at Heathrow right now has perfect logbooks. IF you can find the logbooks all the way back, which usually you can't.

[smarthawke]

Note to self, write in more detail...! Any work carried out on the aircraft (and its components) and parts fitted should be recorded in the aircraft logs and all paperwork kept on file - ADs, checks, anything.

But, you're absolutely correct that this isn't always the case - one reason why pre-purchase surveys include log book studying but with the proviso that people only write in them what they want others to see. The unscrupulous may not include the fact that they have fitted bogus parts, not shockload inspected the engine after a prop strike etc.

One of the facts of life is that the CAA surveyors concentrate more on the paperwork side of things than the actual physical state of the aircraft (although they do love checking placards during surveys!). A number of engineers have had their licences revoked or suspended and maintenance organisations had their approvals cancelled because of paperwork irregularities. Part-M brings even more paperwork, particularly during the organisation approval process and those that struggled to maintain their M3 approvals have little chance of surviving the path to Subpart F and G....

So as my colleagues have stated, we do what we feel we have to do (ask the CAA and they'll say non-commitally 'interpret the rules as you see fit') to keep the aircraft flying safely, our customers happy and the lawyers away from the door!

[A and C]

bose-x

Quote

Sometimes some of you lot are cheeky judgemental bastards who only looking for a fight half read stuff. Quick to fire a response with half the facts.

The fact is that you seem to want to have your engineers risk financial ruin and may be jail by breaking the rules set down by the authoritys to save you a few quid on aircraft maintainence.

I can assure you that in the case of an accident the victims lawers would have a field day with anyone who was unlucky to have released an aircraft to service under the Bose-X maintenance schedule.

From a technical perspective I also find you judgment a little unlikely, 1500 hours from a Vac pump is getting on for three times the recomended life of all the carbon vane pumps built today, I can only put the longevity of this pump down to a miracle of biblical proprtions or an error in your techincal records.

Good practice on the part of your CAMO will save you from the latter error but I should not count on devine intervention as a basis for airworthiness.

[AC-DC]

Code:

Quote:
As a comparison, under EASA I am facing:

Prop Overhaul for a prop that has 700 hours on it from new.
Mag overhauls because they are over 500 hours
Vac pump replacement at 500 hours
Seat belts replacing as they are 10 years
Static lines replacing  

I believe even under N reg rules all of the above items are still required and it is a US manufacturers specification that demands that they be done. In effect EASA are just implementing what the US manufacturers edict in the first place.

For non commercial these are recommendations only so you can fly your prop. for as long as you want.

[S-Works]

The fact is that you seem to want to have your engineers risk financial ruin and may be jail by breaking the rules set down by the authoritys to save you a few quid on aircraft maintainence.

No A and C, what I want is my engineers to be allowed to exercise the professional judgement that they have done for decades and like they are still allowed to do under other regimes. If you can provide me with a safety case that says the FAA are getting it wrong by allowing the engineers to exercise that experience then we can talk.

In the meantime were you one of the Part M companies that I talked to that gave me the truth as it suited them?

[A and C]

bose-x

I doubt if we have talked to you about any maintenance services as we usualy work with aircraft of more exotic construction (however we do have a number of Cessna's on the books).

We would of course be pleased to offer you Part G, F services or both if you should require it.

[jxk]

bose_x

Just to show how helpful I can be check the following CAA website for those organisations with Part M subpart G:
Approved Organisations | Operations & Airworthiness | Safety Regulation

Regards

[S-Works]

Thanks JXK, but I had already been down that route and spoke to half a dozen companies as well as the CAA. It was not a lack of organisations, rather it was a lack of cohesive answers from some of them. Some in direct opposite to what the CAA were telling me.

On the bright side I have spoken to 3 organisations via these forums who have al told me the same story independently and that matches the CAA statement.

One of those will be doing the work for me. I will not being going into a 'controlled' environment though.