The end of LAMP
Thread Starter
Joined: Jan 1999
Posts: 6,209
Likes: 2
From: north of barlu
The end of LAMP
As some of you might know the UK CAA have been found not to comply with EASA standards for maintenance by letting the UK GA fleet use the CAA Light Aircraft Maintenance Programe.
LAMP was intended as the EASA compliant version of LAMS !
So guys you can expect in the next year or so your maintenace providor to have to write a new maintenance program for your aircraft, this will be based on the manufactuers maintance program with the usual EASA additions.
I would guess the cost of writing the new maintenance program will be about £400 as the CAA application form runs to 13 pages and no doubt the CAA will add something for the program to be approved.
LAMP was intended as the EASA compliant version of LAMS !
So guys you can expect in the next year or so your maintenace providor to have to write a new maintenance program for your aircraft, this will be based on the manufactuers maintance program with the usual EASA additions.
I would guess the cost of writing the new maintenance program will be about £400 as the CAA application form runs to 13 pages and no doubt the CAA will add something for the program to be approved.
Joined: Jan 2002
Posts: 1,235
Likes: 0
From: Niort
I have the advantage of operating a permit to fly aircrat (LAA). However it has a type specific maintenance program - because why would you use a generic programme which does not address the specific requirements of the equipment installed and the relevant airframe requirements (some of which are very specific to the modificaiton status of my aircraft).
Bluntly if the CAMO is going to charge for a type specific maintenace program - which is provided by the type approval hoder - they deserve to be charged with fraud! As to the CAA 'approving' it? Oh dear!
Bluntly if the CAMO is going to charge for a type specific maintenace program - which is provided by the type approval hoder - they deserve to be charged with fraud! As to the CAA 'approving' it? Oh dear!
Joined: Aug 2003
Posts: 1,579
Likes: 0
From: Not a million miles from EGTF
The CAA take the view that 'the user pays'.
This tends to mean (as it does in most governmental agencies) that the end user stumps up even if the regulator screws up. It shouldn't do, but this bunch of incompetents aren't going to help us out.
This tends to mean (as it does in most governmental agencies) that the end user stumps up even if the regulator screws up. It shouldn't do, but this bunch of incompetents aren't going to help us out.
Joined: Apr 2008
Posts: 555
Likes: 0
From: Cilboldentune, Britannia
Until recently I owned a 1954 Cessna: the only maintenance program I could find was a 100 hour inspection as detailed in the POH ( the 100 hour inspection to be carried out at 100 hours or annually). So, would it be necessary to do a 50 hour/6 month check (as now) and could EASA/CAA make changes to the maintenance schedule in contradiction to the manufacturers (design authority) instructions?
Joined: Jan 2002
Posts: 1,235
Likes: 0
From: Niort
For a 1954 airframe the maintenance schedule is unlikely to be the 'original'. Or at least it should not be! You are of course also neglecting the engine - which with a date like that will probably have oil replacement at 25 to 30 hours and many of the other requirements at much more frequent intervals than we would use today.
In cases like this there is some justification in there being costs associated with a type specific maintenance program. That is because it will start with the originals and then can be modified as a result of 50 odd years of experience of running the type. The diffficulty is that very few 'maintenance organisations' have any idea on how to compile a justifable program - because all they have every done is lean on LAMS, LAMP etc and added ADs on the top.
But there are resources available and I suspect the US owners club is probably a very good source of information in your case.
Of course it does make something of a nonsense of the whole Part M approach - because if you ask the type approval holder for a type specific maintenance program they will tell you they no longer support that type......
In cases like this there is some justification in there being costs associated with a type specific maintenance program. That is because it will start with the originals and then can be modified as a result of 50 odd years of experience of running the type. The diffficulty is that very few 'maintenance organisations' have any idea on how to compile a justifable program - because all they have every done is lean on LAMS, LAMP etc and added ADs on the top.
But there are resources available and I suspect the US owners club is probably a very good source of information in your case.
Of course it does make something of a nonsense of the whole Part M approach - because if you ask the type approval holder for a type specific maintenance program they will tell you they no longer support that type......
Thread Starter
Joined: Jan 1999
Posts: 6,209
Likes: 2
From: north of barlu
gasax
Quote:-Bluntly if the CAMO is going to charge for a type specific maintenace program - which is provided by the type approval hoder - they deserve to be charged with fraud!
At first sight you would think so, but the CAA are taking the view that the maintenance progran will have to be customised for each individual aircraft (due to eqipment fit) and this requirews that the equipment manufactures maintenace program has to be used insted of LAMP.
The cost comes because this data has to be put into a program and then sent for CAA approval via the 13 page form, You cant expect any CAMO to do this for free.
In my view there is no safety case for the changes, if you view the safety record of other EASA states they fail to match the safety record of the UK CAA so the only reason for the changes are to keep the so called European Air Safety Agency in work.
At first sight you would think so, but the CAA are taking the view that the maintenance progran will have to be customised for each individual aircraft (due to eqipment fit) and this requirews that the equipment manufactures maintenace program has to be used insted of LAMP.
The cost comes because this data has to be put into a program and then sent for CAA approval via the 13 page form, You cant expect any CAMO to do this for free.
In my view there is no safety case for the changes, if you view the safety record of other EASA states they fail to match the safety record of the UK CAA so the only reason for the changes are to keep the so called European Air Safety Agency in work.
Joined: Jan 2007
Posts: 343
Likes: 0
From: Pembrokeshire UK
There is a source of up to date type specific maintenance programmes that have been in use for years... France.
EASA part M is based on the old French system which has long used the concept of 'controlled' & 'uncontrolled' environment.
All French registered & certified aircraft will have been maintained under an approved type specific programme. Under part M those programmes were simply adopted by EASA under a form of grandfather rights. So any CAMO which wishes to obtain a fully up to date type specific and equipment specific maintenance programme will find them in the files of OSAC. But of course they are written in French which is one of the EUs official languages. Seems fair enough to me, we make French pilots speak English, so now our engineers should fix aircraft using French programmes.
EASA part M is based on the old French system which has long used the concept of 'controlled' & 'uncontrolled' environment.
All French registered & certified aircraft will have been maintained under an approved type specific programme. Under part M those programmes were simply adopted by EASA under a form of grandfather rights. So any CAMO which wishes to obtain a fully up to date type specific and equipment specific maintenance programme will find them in the files of OSAC. But of course they are written in French which is one of the EUs official languages. Seems fair enough to me, we make French pilots speak English, so now our engineers should fix aircraft using French programmes.
Joined: Aug 2003
Posts: 1,579
Likes: 0
From: Not a million miles from EGTF
Just curious, but as part of the initial issue of the non-expiring CofA and ARC issues, I think we owners would have paid for the development of the individualised maintenance programme.
Is it ours and when we move CAMOs does it come with us, or is it something each CAMO holds on to and the next one develops when we change companies?
Is it ours and when we move CAMOs does it come with us, or is it something each CAMO holds on to and the next one develops when we change companies?
Joined: Jan 2007
Posts: 343
Likes: 0
From: Pembrokeshire UK
It IS your programme and part M requires you to have a copy of it and to fully undestand it. It will have your name on it, and at some time you will have signed it to say that you are responsible for the maintenance of your aircraft. You are also able to sub contract that responsibility to an approved organisation.
However the programme you signed (LAMP) is deemed by EASA to be not suited for purpose.
Someone (your CAMO or yourself) will have to obtain an EASA approved type specific and equipment specific programme. These as I have indicated above have long been available in France for all certified aircraft registered in France.
Rather than search for non existant manufacturers programmes (particularly for American or British aircraft) why not obtain the already developed and up to date French programme?
The cost of this should be laid at the doors of the CAA who decided to hang on to the generic LAMS/LAMP; at least they ought to fund the translation costs from French to English.
It is barking mad to try to develop from scratch a new type specifc programme when all the work has already been done by the French.
Two ways we might get a programme?
1. The CAA make an official request to the DGAC/OSAC for access to their files, and make the programmes available (for a fee!)to the UK GA fleet. We (the UK GA owners) personalise the programmes by putting our names on each page and signing the declaration of responsibility. We also acknowledge that only the French original has authority (unless we get a CAA approved translation) and our English translations are for info only. We then submit the personalised programmes back to the CAA for approval and pay them yet another fee.
2. Those of us who regularly fly to France ask the French owners of similar aircraft to e-mail a copy of their approved programme to us. We then get someone (
nice little earner!) to do an English translation. The two programmes English & French are signed and personalised and submitted to the CAA for approval.
However the programme you signed (LAMP) is deemed by EASA to be not suited for purpose.
Someone (your CAMO or yourself) will have to obtain an EASA approved type specific and equipment specific programme. These as I have indicated above have long been available in France for all certified aircraft registered in France.
Rather than search for non existant manufacturers programmes (particularly for American or British aircraft) why not obtain the already developed and up to date French programme?
The cost of this should be laid at the doors of the CAA who decided to hang on to the generic LAMS/LAMP; at least they ought to fund the translation costs from French to English.
It is barking mad to try to develop from scratch a new type specifc programme when all the work has already been done by the French.
Two ways we might get a programme?
1. The CAA make an official request to the DGAC/OSAC for access to their files, and make the programmes available (for a fee!)to the UK GA fleet. We (the UK GA owners) personalise the programmes by putting our names on each page and signing the declaration of responsibility. We also acknowledge that only the French original has authority (unless we get a CAA approved translation) and our English translations are for info only. We then submit the personalised programmes back to the CAA for approval and pay them yet another fee.
2. Those of us who regularly fly to France ask the French owners of similar aircraft to e-mail a copy of their approved programme to us. We then get someone (
nice little earner!) to do an English translation. The two programmes English & French are signed and personalised and submitted to the CAA for approval.
Last edited by vee-tail-1; 29th July 2011 at 11:44.
Joined: Mar 2006
Posts: 262
Likes: 0
From: very west
I am one of those who didn't know...and I am a CAMO!!!
Often over the last XXXX years, I have made comments to my Regional Office about the lack of dessemination of information to industry, especially for those of us in the edge of nowhere. I am on the FAA and EASA mailing list for AD's, and the CAA mailing list for everything and I filter it out myself, attempting to ensure I am up to date with changes. In this way, I can attempt to ensure my staff, customers and friends are kept fully informed as soon as something of note comes along. Great plan, you may think.
However, It always seems that I find out things from various forums, phone calls from friends, and other second-hand methods.
Today is no exception.
E-mail sent to my CAA Surveyor asking for conformation.
camlobe
Often over the last XXXX years, I have made comments to my Regional Office about the lack of dessemination of information to industry, especially for those of us in the edge of nowhere. I am on the FAA and EASA mailing list for AD's, and the CAA mailing list for everything and I filter it out myself, attempting to ensure I am up to date with changes. In this way, I can attempt to ensure my staff, customers and friends are kept fully informed as soon as something of note comes along. Great plan, you may think.
However, It always seems that I find out things from various forums, phone calls from friends, and other second-hand methods.
Today is no exception.
E-mail sent to my CAA Surveyor asking for conformation.
camlobe
Joined: Nov 2005
Posts: 59
Likes: 0
From: MIA
camlobe
Neil Williams (CAA Airworthiness Strategy and Policy Dept) announced it at the seminar at Sywell last Wednesday. Apparently each aircraft's individual maintenance program will need to be approved by the time of the first AR after April 2012. No more details of how it will work, but he did say to the assembled "this is a business opportunity for you guys" which, as an aircraft owner/operator, sent shivers down my spine!
g
Neil Williams (CAA Airworthiness Strategy and Policy Dept) announced it at the seminar at Sywell last Wednesday. Apparently each aircraft's individual maintenance program will need to be approved by the time of the first AR after April 2012. No more details of how it will work, but he did say to the assembled "this is a business opportunity for you guys" which, as an aircraft owner/operator, sent shivers down my spine!
g
Thread Starter
Joined: Jan 1999
Posts: 6,209
Likes: 2
From: north of barlu
Silvaire1
You quite clearly have missed the point you are working under a mature regulatory system that is subject to public scrutiny and uses a light touch to regulate the industry.
EASA is only about providing European jobs and keeping the paperwork flowing so as to maintain those jobs............... It has nothing to do with aircraft safety whatsoever if it had the UK CAA LAMP system would stil be in place as it has provided a l level of safety that is better than a lot of the EU states that are mandating this change.
EASA is only about providing European jobs and keeping the paperwork flowing so as to maintain those jobs............... It has nothing to do with aircraft safety whatsoever if it had the UK CAA LAMP system would stil be in place as it has provided a l level of safety that is better than a lot of the EU states that are mandating this change.
Joined: Jan 2007
Posts: 343
Likes: 0
From: Pembrokeshire UK
A & C it's not much compensation for us, but the French owners I have met seem pretty bras...d off with EASA as well. Under their old system owners could do most maintenance themselves quite legally, and sign an APRS (CRS). Appendix VIII (permitted pilot/owner maintenance) seems a pathetic gesture of compensation to them.
Joined: Jun 2011
Posts: 47
Likes: 0
From: England
Maybe this can shed some more light on the discussion, seems a little contradictory in places where it talks about modifying the LAMPs and then replacing it?
http://www.caa.co.uk/docs/33/2011062...mentOfLAMP.pdf
Guess we shall wait and see.....as per usual.
http://www.caa.co.uk/docs/33/2011062...mentOfLAMP.pdf
Guess we shall wait and see.....as per usual.
Joined: Feb 2006
Aviation Qualifications: LAME
Posts: 36,145
Likes: 5,739
From: Falling off the end of the thread
Lamp's always was amended to the individual aircraft, I had to fill a copy out in the back of the logbooks and add additionals to tailor it to the individual aircraft.
But to be honest when all the mandatory maintainance requirements were added to take into account the type certificate holders requirements it became stupid, you then had the situation where you were having to add for example Cessna's maintainance time limits to Lamps. As the US system is based on 50 hr and 100 hr cycles and the 100hr also covering the Annual and the Uk was based on a 1st 50hr, 2nd 50hr, 150hr and Annual cycle you would find you would need to do stuff like tappet clearances etc at 100hrs as that is the Type Cert Holders specified time limits, even though LAMPS was on a 150hr Cycle........ so you end up with trying to merge two different hourly systems........ the only way round it was to write an individual maintainance programme for each type and get it approved, but you would then have to justify and get passed the deviation from the type holders life or time limits, and I wish you luck there.
Now I could fully understand this if there was conclusive proof of aircraft dropping out of the skies because of this not being carried out evey 100 hrs, but truth be told the majority of the UK light aircraft fleets having operated over 20 years plus on a 150 hr cycle have proved this not to be the case.
All of this would be fine if Cessna did their job and actually updated the manuals, the SL about teflon brake hoses came out in 85 and was supposed to be updated in the manual..... still awaiting that one, the aileron balancing in the 152 manual still has the wrong ailerons and figures too!
Seat belts are the other classic fopar in putting a must replace life on them, fine if it was accurate across the fleets, but it isn't you end up changing belts on a 150 but not on a 152 that uses the same belt..... also even though the belt manufacturer do not give it a life, Cessna do.
You could also have the situation of say a Cessna 150 privately owned, kept in a heated darkened hangar and flown say 40 hours a year by just the owner who then has to replace the passenger seatbelt that has never ever been used on calender time, even though no one ever sits in the seat and the belt has never been used....... ludicrous.. We used to proof test these and can anyone explain why we no longer can??
And don't get me started on Teflon engine hose lifes on the likes of Cessna's powered by Lycomings, where other manufactures put those hoses on Condition!
EASA and the CAA have lost the plot...... Engineering licences are another one, fine go over to an all encompassing EASA licence, but please explain WTF we have Annex 2 aircraft and have to retain a licence for those???? As far as I can see it was just to justify keeping staff on at the CAA.. all aircraft should have been transferred to the EASA licence and the CAA as such should have ceased to exist as an independant body... and now with the future light stuff they are looking at a third licence..... It is bureaucracy gone mad!!!!!!
But to be honest when all the mandatory maintainance requirements were added to take into account the type certificate holders requirements it became stupid, you then had the situation where you were having to add for example Cessna's maintainance time limits to Lamps. As the US system is based on 50 hr and 100 hr cycles and the 100hr also covering the Annual and the Uk was based on a 1st 50hr, 2nd 50hr, 150hr and Annual cycle you would find you would need to do stuff like tappet clearances etc at 100hrs as that is the Type Cert Holders specified time limits, even though LAMPS was on a 150hr Cycle........ so you end up with trying to merge two different hourly systems........ the only way round it was to write an individual maintainance programme for each type and get it approved, but you would then have to justify and get passed the deviation from the type holders life or time limits, and I wish you luck there.
Now I could fully understand this if there was conclusive proof of aircraft dropping out of the skies because of this not being carried out evey 100 hrs, but truth be told the majority of the UK light aircraft fleets having operated over 20 years plus on a 150 hr cycle have proved this not to be the case.
All of this would be fine if Cessna did their job and actually updated the manuals, the SL about teflon brake hoses came out in 85 and was supposed to be updated in the manual..... still awaiting that one, the aileron balancing in the 152 manual still has the wrong ailerons and figures too!
Seat belts are the other classic fopar in putting a must replace life on them, fine if it was accurate across the fleets, but it isn't you end up changing belts on a 150 but not on a 152 that uses the same belt..... also even though the belt manufacturer do not give it a life, Cessna do.
You could also have the situation of say a Cessna 150 privately owned, kept in a heated darkened hangar and flown say 40 hours a year by just the owner who then has to replace the passenger seatbelt that has never ever been used on calender time, even though no one ever sits in the seat and the belt has never been used....... ludicrous.. We used to proof test these and can anyone explain why we no longer can??
And don't get me started on Teflon engine hose lifes on the likes of Cessna's powered by Lycomings, where other manufactures put those hoses on Condition!
EASA and the CAA have lost the plot...... Engineering licences are another one, fine go over to an all encompassing EASA licence, but please explain WTF we have Annex 2 aircraft and have to retain a licence for those???? As far as I can see it was just to justify keeping staff on at the CAA.. all aircraft should have been transferred to the EASA licence and the CAA as such should have ceased to exist as an independant body... and now with the future light stuff they are looking at a third licence..... It is bureaucracy gone mad!!!!!!
Last edited by NutLoose; 31st July 2011 at 22:02.