Confused about ARC CofA EASA etc

[jxk]

IO - I think you'll find that a Part M (G) is responsible for making sure that all previous work on the aircraft is valid. It's not good enough to say, "it came in like that"! This is why it's so important that log books reflect the official history of the aircraft by the way of minor/major mods etc. Keep up the thought provoking posts though. There's a world of difference between what we think we would like our universe to be and the real and legal reality. I'll vote for you next time

[IO540]

I think you'll find that a Part M (G) is responsible for making sure that all previous work on the aircraft is valid. It's not good enough to say, "it came in like that"! This is why it's so important that log books reflect the official history of the aircraft by the way of minor/major mods etc

Surely that's impractical. Any plane which is say 30 years old (the bulk of the UK spamcan fleet) has had loads of stuff done to it in years gone by which is not in the logbooks.

For starters, you would have to trace every wire and compare it with the wiring diagram from that era. Nobody does that. You do due diligence - a good legal defence in the UK. For strict liability.... well, that's what insurance is for.

But I was not referring to the logbooks, earlier. I was going on about the need to have manufacturer's "latest" maintenance data.

[cessnapete]

IO540

I think you will find CAA/EASA can do just that.
The Fighter Collection G reg a/c at Duxford have been grounded by the CAA for over a year for paperwork problems of past work done.
Nothing to do with safe flying-just bulls...!!

[IO540]

I don't disagree they have the power but if they did that across the board, much of the ageing GA fleet would be grounded, pending re-certification.

[englishal]

The biggest factor is having a hangar where you can work without restrictions.

We have no restrictions, and about 30m away, just across the taxiway is an FAA IA....We can swap hangars for a week if you want

[jxk]

Surely that's impractical. Any plane which is say 30 years old (the bulk of the UK spamcan fleet) has had loads of stuff done to it in years gone by which is not in the logbooks.

IO - I know what you're saying. But for instance, as I understand it, the MOs have to ascertain whether every relevant AD has been complied with. If it's not recorded in the log-book it may be that the aircraft has to be stripped down until it can be proven that it's done.
A good example was the fiasco over engine oil pumps, there were several changes to the oil pump 'rotors' and the only way of telling which was fitted was to strip the engine down. A more current engine AD is the valve guide issue, in other words whether the latest chrome guides are fitted; cylinders should have been stamped with a 'C' but if not it means removing camshaft covers and measuring the wear.

It's hard but it's tough job to fight bureaucracy.

[IO540]

the MOs have to ascertain whether every relevant AD has been complied with.

Indeed but checking ADs is very different to what has been said earlier which was checking the a/c did not have any mods done off the logbooks - ever.

Checking ADs is often safety critical, and even the "pointless" ones are usually manufacturer's SBs which are generally worth doing.

I know of some Socata and Honeywell SBs which were bollox (oil pressure sensor, autopilot) because they were written by people who didn't understand the subject, but most SBs have a reason behind them. Usually the ones which would have affected in-warranty aircraft were called "non-mandatory" because only "mandatory" ones were warranty covered

IMHO, anybody who ignores ADs which are safety critical is a plonker.

Equally, anybody who gets ADs implemented and doesn't make sure the work is logged is a fool because his plane will be worth so much less when he tries to sell it. Unfortunately, most people rely on their MO to keep the logs and they rely on the MO to not disappear with them after a few years. I have had my plane just 8 years and have already had three firms (that did important work) disappear; luckily I retrieved the records long before they went down. Air Touring, CSE, one other. I think owners need to be a lot more pro-active on this front than most of them are. Even taking copies of each Annual's work pack is highly desirable.

[jxk]

IO -

I think owners need to be a lot more pro-active on this front than most of them are. Even taking copies of each Annual's work pack is highly desirable.

I couldn't agree with you more. It's amazing how slack people are with keeping their log-books up to date and scheduling their servicing (50/100hrs/6 month).

[ferrydude]

Re manuals, sure, the FAA too in theory requires the latest manuals, but the "fact" is that most firms do not subscribe to the latest $1000/year ATP CD manuals for every type they work on. Many work off many years old microfilms. The GA maintenance scene would grind to a halt if this was actually enforced. It would also make a mockery of all owner maintenance provisions.

To clear the air, it is not an oversight of enforcement that allows firms, or individuals to perform maintenance without using the most current mfg's manual.

It is clearly stated in 14 CFR part 43.13.

§ 43.13 Performance rules (general).

(a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator,

In fact, most maintenance manuals for light GA aircraft are not even FAA approved.

It is perfectly legal to use an outdated manual as part of "other methods, techniques, and practices acceptable to the administrator"

[IO540]

That's really interesting... I know of one chap who runs a particular owners group site who has been banging on about this (needing the latest manual even for owner/pilot maintenance) for years and nobody has challenged him.

Personally, I and many others have picked up very recent "used" ATP CDs on Ebay but Ebay shuts down those sellers pretty fast.

[happybiker]

Very interesting

Part 145.A.45 Maintenance data

(g) The organisation shall establish a procedure to ensure that maintenance data it controls is kept up to date. In the case of operator/customer controlled and provided maintenance data, the organisation shall be able to show that either it has written confirmation from the operator/customer that all such maintenance data is up to date or it has work orders specifying the amendment
status of the maintenance data to be used or it can show that it is on the
operator/customer maintenance data amendment list.

[IO540]

I think there are three relevant angles on this in Europe:

1) Since many manufacturers have given ATP a sole agency for the publication of their MMs, any EASA reg which simply mandates the "latest data" will be illegal under EU law, in the same way that "mandatory handling" is illegal unless there is more than one handling agent (the fact that multiple handling agents will probably run an illegal price fixing cartel, or behave de facto as if they were doing that as a result of the airport's dictat on using pricing to exclude GA, notwithstanding).

2) Sole agencies have been illegal in the EU for many years so ATP being the sole publisher is illegal over here (though not illegal in the USA and elsewhere)

3) Due Diligence is a defence in UK law and so any system where you have less than latest data, but have some way of obtaining a list of changes (that are relevant to the work being done) should be legit.

[ferrydude]

Not all aircraft repair shops are Repair Stations certificated under Part 145. Different rules apply. 145 certificated agencies ARE required to have the most current manuals, and I don't think IO540 was referring to these agencies. I seriously doubt anyone would find a 145 agency using outdated manuals, fiche, etc.

On the other hand, a non 145 shop would be using individual A&P Mechanics for returning aircraft to service. Different requirements as far as manual currency and data required for maintenance. It is not uncommon to find manuals in use that are not the latest revision. Perfectly legal if you know, and understand the requirements.

[IO540]

This being a mainly UK forum, there are very few FAA Repair Stations over here. Those that there are tend to be expensive, or concentrating on the higher value end of the market, it appears.

[ferrydude]

Indeed, the added expense stems from compliance with the associated part 145 requirements. One of which is the requirement to have all of the current data for aircraft/items maintained.

[LowNSlow]

As an owner of one of the lower end aeroplanes, an Auster Autocrat, I can testify that I have seen a major difference in my Annual costs since moving from an Annex II C of A to a Permit.

2009 Annual - £2,000. No major work done.
2010 Annual - £800.

The work was done by the same chap but in 2009 all his work had to have another Licensed Engineer to do the duplicate checks plus send a wodge of paperwork to the CAA.

[IO540]

Can you post the breakdown of work charged for, for both annuals?

I don't know what an Auster even looks like (could google for an image I suppose ) but a normal 4-seat spamcan is about 30-40 man-hours for the annual.

[LowNSlow]

It's a high winged 2-4 seater. 100hp inline 4 cylinder engine, steel tube and fabric fuselage and tail, wooden spar, ally ribs and fabric covered main planes. Very basic radio fit (no generator, radio run off batteries), basic instrumentation. Think Piper Cub or Taylorcraft.

Inspection as per LAMS which is pretty simple for an Auster, just pop all the inspection covers and have a root around. There's not a lot to wear out! She only does about 40 hours/year max and lives in a heated weatherproof hangar.

Valve clearances set, plugs cleaned and gapped, mag timings checked, oil changed, compression check.

That's about it. As you say around 30 hours labour and sundries. Easy on a Permit, unnecessarily expensive when on a C of A due to the extra paperwork/licensed engineers signatures.

[Justiciar]

I dont know what your cost of parts was but on that basis you appear to be paying around £20 to £23 per hour for 30 hours of work. Is that right?

[IO540]

The thing is, LowNSlow, what hourly rate are you paying for the 30 hours?

Most rates are about £50-60/hr which works out at £1500-1800, yet you say you pay £800.

These "LAA v. CofA" debates surface periodically (yes another long one running on flyer right now) and every time people are comparing apples and oranges. I have written enough on this so won't do so again but it always comes down to a comparison which is based on very different working arrangements and working practices e.g. owner maintenance, people doing one favours, people working cheaply for cash, etc.

Like I said before (many times) if I had a hangar where I could do my own work, I would halve the cost of my Annuals, and everything would still be 100% legit (it would be done by an A&P or A&P/IA working on the side). But such hangars are extremely scarce at the sort of airfields where the owners of the more capable aircraft are based.

If you had two examples of the same hardware, one LAA and one CofA, the cost of an Annual could not be very different. The former would be a few hundred quid cheaper due to various factors but not the huge factors normally claimed by Rod1 and some others.