ARC and EASA

[tb10er]

Has anyone had any experience of this?

Our maintenance company have advised us that we will require a "back to birth" audit of all serial numbers, etc. on our aircraft. We also have to ensure that all log books, etc. are available since the aircraft was built.

What are your experiences?

[S-Works]

What are your experiences?

That a good number of maintenance organisations are hiding behind the Part confusion to drop a lot of peoples pants........

[robin]

.. but the Belgrano rolled over first, and are not likely to help the rest of us getting stuffed

[Malcom]

[vee-tail-1]

If your maintenance company decides to use a 'big shovel' you can expect a big load of sh**t
Try a company with a smaller shovel.

ARC ISSUE / RENEWAL CHECKLIST.

Documents to be provided by owner / operator:

- REGISTRATION CERTIFICATE, C of A, ARC,
- FLIGHT MANUAL.
- APPROVED MAINTENANCE PROGRAMME.
- CONSTRUCTORS MAINTENANCE MANUAL.
- AIRFRAME, ENGINE, & PROPELLER, LOGBOOKS & DATA SHEETS.
- ROUTE LOGBOOK.
- STATE OF REPAIR OR MODIFICATION.
- STATE OF MAINTENANCE PROGRAMME CONFORMITY.
- STATE OF ADs
- STATE OF WORK REPORTS [SBs, SLs, replacements, etc]
- WEIGHT & CG REPORT.

Examination of Documents:

- FLYING HOURS OF AIRFRAME, ENGINE, & PROPELLER ARE PROPERLY RECORDED.
- FLIGHT MANUAL IS APPROVED AND CONFORMS TO THE AIRCRAFT CONFIGURATION.
- REQUIREMENTS OF MAINTENANCE PROGRAMME ARE COMPLIED WITH, including life limited components.
- M.P. ERRORS ARE CORRECTED, REPORTED, AND APPROVED.
- ADs ARE COMPLIED WITH AND PROPERLY RECORDED.
- MODS & REPAIRS ARE PROPERLY RECORDED& APPROVED.
- WEIGHT & CG REPORT CONFORMS TO THE AIRCRAFT CONFIGURATION.
- ALL MAINTENANCE WORK CONFORMS TO THE REQUIREMENTS OF PART M.


Aircraft Physical examination:

- Presence of required marks and placards.
- Aircraft configuration conforms with Flight Manual.
- Design of aircraft conforms to EASA type approvals.
- No faults apparent other than those reported and approved.
- There is no inconsistency between the aircraft and documents examined.

[S-Works]

How else do you prove that the serial number of every part fitted matches the log book except by a huge inspection.

You don't have to. The aircraft has a valid CofA, the last engineer to inspect and give it a CofA is certifying to the aircraft has been maintained correctly and that all AD's etc have been complied with. Under Part M they are only required to go back to the last CofA to ensure any work or parts applied is compliant.

Hence the comments here and in other place about the 'interpretation' that some maintenance companies are putting into the rules.

Some I have talked to are interpreting the rules in the correct manner, others are not and some are just using it as an opportunity to drop peoples trousers.

[vee-tail-1]

Present this form to your CAMO. If they refuse find another one.

Note to inspecting persons in the Sub Part G & I organisation:

There is no requirement by EASA for a ‘Back to Birth’ inspection of documentation in order to issue an ARC.

It will normally be sufficient to start airworthiness review inspections at the issue or renewal of the last NAA Certificate of Airworthiness.

The relevant date and flying hours for G-A...... are therefore:

............... Date at ............... Hours.
Logbooks & documentation from and including these dates and times are available from the owner/operator. Documentation before these dates and times will not be made available.

The aircraft is presented to you for issue of an ARC on the understanding that you agree with the above conditions.

Signed………………. CAMO official.

[robin]

Who is going to be brave enough to be the first to use that form???

[A and C]

Back to birth!

NO WAY!

However an audit of all the time life items is required.

As usual someone says that you "only" have to go back to the last C of A but this won't wash if the last guy made a mistake.

What is happening is the maintenance companys who did half the job for 75% of the true price are being outed and the customers of these companys are screaming like stuck pigs because they are now having to pick up the cost of years of shoddy maintenance.

[S-Works]

As usual someone says that you "only" have to go back to the last C of A but this won't wash if the last guy made a mistake.

I am sorry but that does not wash either. It is the last guys responsibility not the new guys. The words from the CAA are that the engineers go back to the last CofA and nothing more. Routine check on lifed items.

If you believed every engineer they will tell you that they always do a better job than the last guy!!!!

[IO540]

but this won't wash if the last guy made a mistake.

I thought that maintenance was done on the basis that the previous engineer was trusted. Otherwise, everything is back to birth, every time. Whe is the line to be drawn?

What is happening is the maintenance companys who did half the job for 75% of the true price are being outed and the customers of these companys are screaming like stuck pigs because they are now having to pick up the cost of years of shoddy maintenance.

I suppose a lot depends on whether the last company's invoice states what was done, but it can be shown that it wasn't all done. In that case, the MO is liable.

But what happens in the (many) cases where there was tacit collusion between them and the owner (to keep costs down)? I believe this is common in the flight training business, where the paperwork has to look good but the school doesn't want to pay more than necessary. Tricky.....

The other thing is that the rules can never clearly draw the line at the previous service, because that could be used to circumvent a lot of stuff. If you have done an unauthorised (but obvious) mod, you just make sure you change the MO for the next service and they would not be able to question it I have no idea how this could be resolved formally.

[BackPacker]

Article on this in the latest edition of Flyer magazine. If you're just tuning in into the whole CAMO / EASA Part M issue, it's not a bad place to start.

[Malcom]

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.

[Malcom]

Veetail, no need for the form, just a note to ARC signatory saying youve had a butchers at the plane and docs and everything is hunky-dory and just sign the damm ARC please and thank you.
Cant see the problem for all those prison cell walls!

[vee-tail-1]

This is getting silly. It is impossible to go back to birth with some aircraft, the documentation simply isn't there. To cross check every part and every part number would mean dismantling the whole aircraft. But paranioa seems to be gripping some MOs. Is it the case that for example: If a 30 year old spam can crashes into a school/hospital etc, and the cause is found to be something that should have been done 25 years ago. But the people who signed up the ARC are held to be liable? How could they possibly know if no paperwork was available. There has to be a line drawn beyond which no liability can be incurred, and that line is logically the last C of A inspection.

[NutLoose]

vee-tail-1This is getting silly. It is impossible to go back to birth with some aircraft, the documentation simply isn't there. To cross check every part and every part number would mean dismantling the whole aircraft. But paranioa seems to be gripping some MOs. Is it the case that for example: If a 30 year old spam can crashes into a school/hospital etc, and the cause is found to be something that should have been done 25 years ago. But the people who signed up the ARC are held to be liable? How could they possibly know if no paperwork was available. There has to be a line drawn beyond which no liability can be incurred, and that line is logically the last C of A inspection.

Whilst I can sympathise with you, It is not paranioa, it is the harsh facts of EASA and whilst you say how can you be held liable for what was carried out 25 years ago? well as the signatory on the ARC I and others are stating that all the inspections on the Aircraft have been carried out, failing to ensure that leaves us all open to prosecution.

One of the main problems stems from EASA's ( note the CAA have diddly squat say in it these days) intrangisence to the requirements as these have really been written in the same terms of an Airline operation. I and others are appalled by some of the content withing LAMPS, such as the requirememnts to replace seat harnesses on Aircraft such as a Cessna 150 WITH NEW every 10 years regardless of usage, the same belts installed in a Cessna 152 do not have this requirement as the manual has not been editied to include it. I do not wish to see owners have to throw good money after bad and it reflects against you as both a Company and an Individual if you are seen to be spending Customers money on items that look like new, but you have to obey the new regulations no matter how distasteful. Various lifed items may well fall under flying hours and with some items say falling at 1000 hrs or less the only way you can ascertain if these have been complied with it either to do a full search through the books or to strip as you put it the aircraft down or replace them.

BOSE X Under Part M they are only required to go back to the last CofA to ensure any work or parts applied is compliant.

Well that gets blown out of the water in the fact that lifed items will often fall out of what was the 3 yearly inspection, A company may well of happily signed out your CofA last time round perfectly legally

1, Because at that time there was no requirement to replace lifed items under LAMS

2, because items where there was a requirement to replace them were in life at that time and would be until the next Annual or C of A

Now under LAMP you have to research the aircraft back to ensure that both of the above have been complied with and now are within the current requirements, hence the need for the books.

Remember you can have your maintenance company submit their own maintenence programme for your aircraft that may remove some of this, it will then be upto the CAA/ EASA to approve it.

Remember no matter how harsh it may seem this research should be a once only thing, once done unless you change companies, it will then just need amendments as new items are added. You think I like spending 2 days of my life trawling through logbooks? I have better things to do.





So I am afraid it is welcome to EASA world I think you should all take a deep breadth, open that Copy of LAMPS that was sent to you and read the words

The owner/operator is responsible for the aeroplane’s continuing airworthiness in accordance with Part M M.A.201.

Owner/Operator Certification Statement
The undersigned undertakes to ensure that the aeroplane will continue to be maintained in accordance with the Programme, Section 3

Responsibilities and Standards.

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 airworthiness of the aeroplane.

Airworthiness life limitations shall be those published by the state of design type certificate holder and supplementary type certificate

holders.


Ohh and VEE-TAIL, I wish you luck finding someone to sign your little piece of paper........... Perhaps you need to pop down to B and Q and pick up some nice white gravel to put around your plane, it will make a nice ornament on a gate somewhere, because no one will issue you an ARC for it with those constraints unless they are stupid. The one good thing though is the CAA would prosecute you too

[IO540]

I think gents you have to remember that

It is not paranioa, it is the harsh facts of EASA and whilst you say how can you be held liable for what was carried out 25 years ago? well as the signatory on the ARC I and others are stating that all the inspections on the Aircraft have been carried out, failing to ensure that leaves us all open to prosecution.

is not UK law. Any prosecution would be done in the UK and you would have the usual defences of due diligence, etc.

This HAS to be the case (i.e. there has to be a backstop, plus UK law applies anyway regardless of the wording of some EASA reg) otherwise the system would be unworkable.

Any residual liability is addressed with insurance and you pay the premium and forget about it. That's how lawyers dentists etc do it.

[robin]

I think gents you have to remember that

Quote:
It is not paranioa, it is the harsh facts of EASA and whilst you say how can you be held liable for what was carried out 25 years ago? well as the signatory on the ARC I and others are stating that all the inspections on the Aircraft have been carried out, failing to ensure that leaves us all open to prosecution.
is not UK law. Any prosecution would be done in the UK and you would have the usual defences of due diligence, etc.

This HAS to be the case (i.e. there has to be a backstop, plus UK law applies anyway regardless of the wording of some EASA reg) otherwise the system would be unworkable.

Any residual liability is addressed with insurance and you pay the premium and forget about it. That's how lawyers dentists etc do it.

Forgive me, but it is the CAA we are talking about and not EASA.

The CAA chose to implement a semi-complete piece of legislation knowing full well it was (and still is) going to be changed to a lighter touch version.
And it will be the CAA that is the judge and jury.

Yes, we could choose to have our day in court but at costs even greater than those of the CAAs.

I would love one of our representative organisations to undertake a judicial review of the implementation of Part M, but..........

[S-Works]

Well that gets blown out of the water in the fact that lifed items will often fall out of what was the 3 yearly inspection, A company may well of happily signed out your CofA last time round perfectly legally

Indeed, but checking the lifed items is not a back to birth inspection. It is a check of the lifed items. On a Cessna there are very few lifed items even under Part M. Everything else should be part of a standard annual, AD checks etc.

[NutLoose]

Bose X please read from the book of words, no where does it say check for the last 3 years or take as read what the other company dealing with the Aircraft during its past life did, it says

M.A.710 Airworthiness review
(a) To satisfy the requirement for an M.A.902 airworthiness review of an aircraft, a full documented review of the
aircraft records shall be carried out by the approved continuing airworthiness management organisation in order to
be satisfied that:
1. airframe, engine and propeller flying hours and associated flight cycles have been properly recorded, and;
2. the flight manual is applicable to the aircraft configuration and reflects the latest revision status, and;
3. all the maintenance due on the aircraft according to the approved maintenance programme has been carried
out, and;
4. all known defects have been corrected or, when applicable, carried forward in a controlled manner, and;
5. all applicable airworthiness directives have been applied and properly registered, and;
6. all modifications and repairs applied to the aircraft have been registered and are approved according to Part-21,
and;
7. all service life limited components installed on the aircraft are properly identified, registered and have not
exceeded their approved service life limit, and;
8. all maintenance has been released in accordance with this Part, and;
9. the current mass and balance statement reflects the configuration of the aircraft and is valid, and;
10. the aircraft complies with the latest revision of its type design approved by the Agency.
(b) The approved continuing airworthiness management organisation's airworthiness review staff shall carry out a
physical survey of the aircraft. For this survey, airworthiness review staff not appropriately qualified to Part-66 shall
be assisted by such qualified personnel.
(c) Through the physical survey of the aircraft, the airworthiness review staff shall ensure that:
1. all required markings and placards are properly installed, and;
2. the aircraft complies with its approved flight manual, and;
3. the aircraft configuration complies with the approved documentation, and;
4. no evident defect can be found that has not been addressed according to M.A.404, and;
5. no inconsistencies can be found between the aircraft and the paragraph (a) documented review of records.

I myself am not a lover of this system, as it is so full of holes and has been left up to the individual companies involved to determine the state of play without sufficent guidance being in place, take a look at some of the Company approvals that have been approved for Aircraft types, some have been issued with Cirrus Piston Engined Singles and Twins below 2730 KG.

Well Cirrus have never and have no plans to build a Piston Twin, so ask me how a Regulatory body can get that so wrong??

Additionally some Companies have been forced to put every single Cessna Model on their approval, whilst others simply put Cessna piston Single and Twins etc.... this is down to a lack of guidance for each Surveyor involved with dealing with the applications.

My personal view is the UK lept into this first instead of adapting the year of grace other Countries did in implementing it, so a year down the line when the rest of Europe is up in arms over it all, there will be further changes to the requirements and hopefully with a dumbing down of some of the requirements.