ARC and EASA

[vee-tail-1]

<< Nutloose 3.1 Certifying persons must use their engineering skill and judgement in determining the depth of inspection needed and other matters, which could affect the airwortiness of the aeroplane >>

At last I am beginning to see the light or rather LAMP/LAMS !

For as long as I can remember GA aircraft have used GENERIC maintenance schedules in the UK. These by their nature required interpretation by engineers as stated above. Engineers could chose to do as much or as little work as they saw fit, and sometimes not enough maintenance was carried out.

In France and other countries by contrast, TYPE -SPECIFIC maintenance programmes have been used. These say what has to be done and when to do it, no interpretation required, and everything laid out clearly in the ATA 100 format. As a result any technically competent person can achieve full and complete maintenance.

If we want to avoid future liability problems, throw out these useless LAMP/LAMS schedules and get a Type-Specific maintenance programme approved for your aircraft.
The French have long been doing this and GSAC will have the relevant programmes on file, for some aircraft probably only in French, but that is one of the official EU languages and we better get used to using it.

Perhaps the paranoia that I see is due to the culture change required in doing things another way. Generic maintenance belongs to a previous age.

[cessnarepairman]

Guy,Guys,

Get a grip. First it was the Millenium bug, then terrorism, followed by bird flu, the credit crunch & now swine flu.

We are either living in fear of the world shutting down due to computer failure, being blown up, loosing our homes or dying of some virulent desease, oh & if you are a licensed engineer being thrown in jail for not following the new EASA rules to the letter.

If you are a conciencious engineer just carry on doing the job like you always have done, no one is going to die because you did not change the seat belts so you are hardly likely to be hauled up before the courts over it. We all know that the CAA will only prosecute if they have a cast iron case against you.

Can anyone remember the last engineer to be found guilty let alone jailed for negligence?. A few years ago a Licenced engineer was tried for a blatent bodge on a helicopter which directly led to the deaths of several people, he was eventually found guilty of "not keeping adequate records"
& as far as I can remember, walked.

As for back to birth investigations, what a load of rubbish, If a part is on a, lets say, 1000 hour overhaul look back through the logbooks 1000 hours, no record of change, then change it. If its a 10 year life, no record,
replace it. Simple. If everyone else has missed it & you then miss it, then it is probably so far hidden in the maintenance schedule that every subsequent engineer/CAMO is going to miss it as well & as such is probably not that important & will not cause a catastrophy.

RELAX!

[A and C]

Vee-tail-1

If you wanted me to change your UK registered aircraft from LAMP to the manufacturers maintenance schedule I would have to get this approved by the CAA, for this they would charge a large amount of money.

And before any of you say that the manufactures schedule for a European aircraft should be approved already by EASA......... well it is but the CAA won't accept it! We have already had this conversation with the CAA and despite schedule being part of the type certificate They say it is "not approved by them for UK aircraft"

I find this situation ridiculous the CAA is not now much more than a regional office of EASA but they can over rule the manufacturers data, could you ever see the FAA office in Detroit suddenly deciding to over rule the rest of the FAA and publish a different maintenance schedule for a Cessna?

[vee-tail-1]

A and C. If that is the CAAs attitude re LAMP & manufacturers Type-Specific schedules, then the mistakes of the past will continue into the future. It's a bit like using a Morris Minor manual as a guide to servicing a BMW, there are bound to be items that are missed. Worse is the fear of litigation under the UK (& USA) adversarial legal system. With generic schedules subject to interpretation by engineers, anything missed could result in an accusation of negligence. Under the UK legal system if a problem occurs someone is assumed to have screwed up and that person must be found and punished. In contrast to the European consensual system which seeks to find the reason for the problem so that it is not repeated. Using my earlier example if a Cessna crashes because some item of servicing was not done in the past, the French would check the maintenance programme to see if the item is in there. If it is then the last engineer to use that programme is clearly at fault. If the item is not in the programme, then no one is at fault and an AD is issued.
I don't know how the present mess is to be sorted out, but it is crazy for engineers to be in fear of litigation for things that they cannot possibly know about due to past use of generic maintenance schedules.

[IO540]

And it will be the CAA that is the judge and jury.

No, the UK Courts will be, and the past shows that the CAA is generally (not always, sadly) pretty smart in knowing what cases they can win.

I think cessnarepairman has it exactly right.

If a part is on a, lets say, 1000 hour overhaul look back through the logbooks 1000 hours, no record of change, then change it. If its a 10 year life, no record, replace it

is how it must work, and that is how it works today (assuming the engineer is the least bit diligent).

As regards TYPE -SPECIFIC maintenance schedules, I have come across this too. Socata planes have this in their maintenance manuals, apparently. The American ones don't but I don't know how one deals with that.

[jxk]

Just out of interest my aircraft has a maintenance schedule included in the POH it requires a 100hr inspection or annual check (same as a 100hr). In my case this would mean only 1 inspection per year as I rarely do more than 100 hrs a year. Can a part G organisation approve this schedule without CAA involvement? The CAA used to charge a fee for approving specific maintenance schedules.

[cessnarepairman]

I know a guy who will draw up a maintenance program for your aircraft based on the manufacturers schedule. He will print off 3 copies, one for you, one for the CAA which he will send to them for approval & keep one for himself.

One of my customers had one drawn up & approved. The cost was about £300 to the author & whatever the CAA cost was. It may not be cost effective in every case but take for example one fairly modern aircraft which we look after. The 50 hour inspection is an oil & filter change, nothing more. If that is what is written in the program then that is all you do, forget about LAMPS.

Another advantage of using a type specific MP is that one can write in all sorts of tasks that can be legally performed by the owner/operator, whether that is a good or bad thing depends on the individual.

The one disadvantage is that you have to follow it to the letter for it to work, e.g. all lifed items & time limited tasks will be written in & must be adhered to. However given the current situation that is what everyone is expected to do anyway.

[jxk]

This rather begs the question, how can the CAA divert from what the manufacturer has ordained as the schedule? How can the CAA override the design authorities programme of maintenance? As I understand it LAMS & LAMP were introduced for aircraft where no maintenance programme existed.
Surely, one should only have to produce the manufacturer's schedule coupled with a list of life items and this shouldn't need any further approval.

[A and C]

I suspect that the CAA refusal to accept EASA approved maintenance Schedules is one of revenue raising and job protection.

[cessnarepairman]

I suppose the key word here is "Approved". Most manufacturers have had schedules in their manuals but they were not "approved" by the CAA.
So the CAA published LAMS/LAMPS which although very generic is approved.

As I previously mentioned there is no problem getting a manufacturers schedule approved, but in my experience in GA most owners will not want to go to this expense.

BTW I have checked with a friend of mine who had a scheduled approved by the CAA & it was FREE!.

[NutLoose]

You all missed what I was saying about searching back, it was in response to the post that you only need to produce a logbook for the last 3 years and that is it. I was trying to show that was not the case.

I heard a while ago that LAMPS may get dropped, it failed in so many ways in my opinion, the main problem was the CAA's desire to be seen as the good guys and keep a version on the go, unfortunately all the baggage that got added made it a pointless exercise, as you cannot simply align the requirements of a 50 50 150 hour regime with a 50 100 50 one, it means you may well end up pulling the thing apart on both the second 50 hr and the 150 hr because the manufacturers manuals require an inspection that you are required to carry out at 100 hrs.

jxk with the hours you do it would not really matter to you as the Annual would fall on the second 50 and would be treated as an annual and not a 50 hr anyway.

A and CI suspect that the CAA refusal to accept EASA approved maintenance Schedules is one of revenue raising and job protection.

Exactly, can anyone tell me why we have Annex 2 aircraft? the only reason they were farmed off in my eyes was for exactly the same reason, it was similar to the MOD situation a few years back where it had to go to the CAA who logged it and then sent it to EASA who actioned it then sent it back to the CAA who logged it as actioned and then returned it back to you........ all that was doing was keeping someone in the loop and hence a job!

[jxk]

Ah but nutloose you miss my point (I think) - that if the manufacturer only specifies 100hr checks then I wouldn't need a 50hr as this seems to be a LAMP requirement.

So only the annual required and that would be the same as a 100hr.

[A and C]

jxk

The manufactures may only have a 100 hour check but unless you meet some very tight requirments you will still have to change the engine oil at 50 hours.

[Malcom]

If only it was as black and white as Bose-x wishes!

I've got a lifed wing on my plane. I've found out its not original, I've no idea how many hours its done. I've no idea when it was changed.

Still, thats OK cos I only need to go back 3 years so I wont be liable in any way shape or form as its had a C of A previously

Quote:
The words from the CAA are that the engineers go back to the last CofA and nothing more. Routine check on lifed items.

Please provide your link to the written word, as that is what will back me up in court when I take over from Half A Job Bob.

[S-Works]

I've got a lifed wing on my plane. I've found out its not original, I've no idea how many hours its done. I've no idea when it was changed.

So you think that the rest of us should suffer for your poor pre-purchase inspection or your poor ongoing maintenance? But please tell us how this back to birth inspection is going to fix the problem?

[robin]

Broadening the point somewhat, it would be interesting to know:

1) Is the CAA required to review the effects of their implementation of Part M or do they have a get-out clause that says they are only doing EASA's bidding, so it isn't necessary?

2) How many engineers have actually ceased trading as a result of Part M

3) How many owners have walked away from ownership thanks to the increasing cost and effects of Part M (combined with the recession).

Even the major airlines are going through massive reductions in activity and are laying off staff. It is little wonder that we (as owners), paying through the nose out of taxed income, are apoplectic with rage.

This half-*rs*d policy gives us nothing we didn't have before but adds to our financial burdens at exactly the wrong moment.

Certainly, if things go as badly for me as they have for some, my lovely little aircraft will soon either be the victim of a major incident (with me alongside)or she will be gracing the 'For Sale' pages.....

[Malcom]

Quote:
I've got a lifed wing on my plane. I've found out its not original, I've no idea how many hours its done. I've no idea when it was changed.
So you think that the rest of us should suffer for your poor pre-purchase inspection or your poor ongoing maintenance? But please tell us how this back to birth inspection is going to fix the problem?

It wont fix it, pretty obviously, the point is if I didnt know before a back to birth review, I would after! T'is hypothetical anyway, anyone not getting a decent pre-purchase check deserves what they get.

But, you still neatly miss the point and avoid the question though!

Quote:
Quote:
The words from the CAA are that the engineers go back to the last CofA and nothing more. Routine check on lifed items.

Please provide your link to the written word, as that is what will back me up in court when I take over from Half A Job Bob.

[jxk]

A & C

jxk
The manufactures may only have a 100 hour check but unless you meet some very tight requirments you will still have to change the engine oil at 50 hours.

Actually 25hr oil change due to not being able to fit a spin-on filter (if this an engine or airframe requirement) but this doesn't mean its a 50hr or 6 month check as per LAMP

[A and C]

jxk

This might help with the oil changes........ is it a Robin?

Oil System Parts

[vee-tail-1]

jxk
I am also curious about your aircraft, having never come across a certified type with only 100 hour checks.