OWNERS the LAMPS Replacement consultation has started

[NutLoose]

This may cost you money, ( read probably will ) so you may wish to get your say, you have until the 16th of next month

See

Consultation - Changes to the Light Aircraft Maintenance Programme | Consultations and Letters of Intent | CAA

[jxk]

This looks like the application of BIG aeroplane principles to LIGHT aircraft and will certainly cause SMALL maintenance companies a LOT of extra work and hence ADDITIONAL cost for the POOR owners. Where is the justifiction for the consultation?

[NutLoose]

Yup in one, and even though the consultation finishes in March it comes into force in April, the saying if it is not broke don't fix it comes to mind... It is not exactly raining aircraft that are falling out of the skies because they use lamps etc is it?

From what I can see it may cost the owner between £ 800 and £ 400 to simply get the new schedule signed off, let alone the cost of writing it.

EASA I believe said LAMPS wasn't legal

[cct]

New LAMPS for old?

Have you tried rubbing it first...

[NutLoose]

It comes into force on April Fools day.... For the CAA how apt.

[vee-tail-1]

For goodness sakes everyone have your say in the consultation.
This is my offering to the CAA:

Dear Sir/Madam

Oh my God! Why do you guys still hang onto Generic maintenance programmes?

First LAMS then LAMP now GMPT! Why oh why do you want to reinvent the wheel?!

EASA part M is based on modification of the old French system. That system from the start used TYPE SPECIFIC MANUFACTURERS MAINTENANCE PROGRAMMES. All French manufactured certified aircraft were (and still are) sold with such programmes. Those non French manufactured certified aircraft that did not have a manufacturers programme (Cessnas, Pipers, and many British aircraft) received an approved type specific, and equipment specific maintenance programme. This programme was developed jointly by the maintenance organisation and GSAC and approved for personal issue to the aircraft owner/operator. Consequently there exists a library of fully up to date type specific maintenance programmes for every certified EASA type light aircraft currently operating in the EU.
These programmes are mostly written in the French language which is one of the official EU languages. I have been maintaining my French Robin EASA aircraft using a French language type specific maintenance programme in accordance with EASA part M rules. The programme is very specific and tells me what to do, when to do it, and how to carry out the tasks. This ensures that any competent aircraft mechanic can achieve full and safe maintenance on any EASA aircraft … a huge increase in safety over the haphazard nature of ‘one size fits all’ generic programmes.
Instead of requiring owners/operators and maintenance organisations to reinvent the wheel by developing yet another maintenance programme …. Just obtain from the French authorities copies of all their existing approved type specific maintenance programmes and issue them to British owners. If the Brits can’t understand French then they can get an approved English translation, but in my experience technical French is not a problem.

What EASA aircraft owners/operators and maintenance organisations/CAMOs don’t need is yet another generic manifestation that will yet again become unfit for purpose. The type specific maintenance programmes for every EASA light aircraft already exist, are fully approved, and have been in use for many years. Why not use them?

[wsmempson]

I don't understand why the CAA would introduce this at almost the exact same moment that Part M, subpart G itself is under review. The likelihood is that by the time this is in place, it'll be time to tear the whole lot up and start again.

[vee-tail-1]

Whatever happens, for safety sake we should all be using the relevant type specific maintenance programmes for our aircraft.
Easy if you own French manufactured types such as Robin, Socata, etc.
You need to open a subscription to the documentation holders: CEAPR for Robin ... then order an English language (or French or German) copy of the Approved Maintenance Programme and the maintenance manual, plus if required, the flight manual, and parts manual.
You will receive a maintenance programme in the ATA 100 format. At the top of each page is a box for the owners name ... you must fill this in with the surname first (Bloggs Joe) on every page of the programme. At the front of the programme is an owner's 'declaration of responsibility for maintenance' under EASA part M rules which must be signed.
This programme is then sent off (in two copies) to the relevant National Aviation Authority (GSAC, CAA,) who check that it is for the aircraft registered in your name, and is the latest issue with all repetitive ADs incorporated. The NAA approves your personalised type specific (for your aircraft only) maintenance programme, keeps a copy and sends you the official version to be used by you or your contracted agents.
The process takes about a week in France, and costs a nominal fee of about ten Euros.
If you own a French aircraft, get hold of the correct maintenance programme, sign it and then become seriously assertive with the CAA and your CAMO and anyone else who thinks they can play fast & loose with the EASA part M rules.

[A and C]

The biggest issue that I can see with this change is that in will in effect make manufactures service bulletins mandatory and not advisory ( as is usually intended with non mandatory SB's).

The way this pans out all rather depends on the way it is implemented, if implemented in a pragmatic way in could be OK, but EASA being the blind, desk bound burocrats gravy train I would have little faith in a reasonable outcome in the short term.

My guess it is will result in a frenzy of removal of serviceable parts on calendar time limitations ( rather than using an on condition basis) with EASA finally relenting after a few years when it becomes clear that the industry is about to disappear and without it the employees of EASA will have no industry to oversee and will have legislated themselfs out of a job ( a bit like the part M overkill that they have been forced to review)

[vee-tail-1]

My guess it is will result in a frenzy of removal of serviceable parts on calendar time limitations

Sadly that fits with my experience and is a definite down side. It really galls to have to junk perfectly serviceable parts ... I did hear of a bit of creative paperwork where time expired but otherwise serviceable parts were swopped between identical aircraft.
However the old generic maintenance programmes allowed LAEs a lot of discretion, to do as much or as little work as they saw fit. One or two appear to have interpreted this as a way to extract money from owners by invoicing them for quite unnecessary work. If owners become very familiar with their type specific programmes (as EASA expect them to be) then it will be difficult for the odd shis**r to rip them off.

[NutLoose]

But the attached info states one of the reasons being to take some of the variance in standards out of it.......


Sorry, BUT you can write the best and most comprehensive maintainence programme in the world that ties the hands of those that work to a higher standard by introducing rules and regulations that make no sense, those that in the past never maintained those standards will STILL NOT do the work, the saying, you can lead a horse to water, but you cannot make it drink... Comes to mind.

An example of what I mean by no sense..


Cessna 152 seatbelts no life

Cessna 150 seatbelts 10 year life NO OVERHAUL

SAME BELTS and more or less same aircraft.

Say an owner has a 150 his aircraft is hangered, he only flies solo 20 hours a year, then every 10 years he will have to as now under lamps be forced to change an unused brand new right hand seat belt that has done 200 hrs.

Previously an engineer would inspect and proof test the belts, he would if required replace the buckles or get rewebbed etc...
That has been removed for no sense whatsoever ever.

Engine hoses, I.E Teflon, Cessna 10 year life, Socata same engines, on condition..
Even the MK 19 Spitfire with an engine that is working to a hell of a different performance and operating standards to a O-235 does not have the limits that Cessna lay down.
LAMS In its way recognised this and set a standardisation, those that came after are a shadow of the former... The CAA and EASA have lost the plot... Still.... legislate the light side of the business out of existance will effect the large side and eventually EASA will falter as well.

[jxk]

#11 Nutloose - I have to agree to everything you said: common-sense no longer comes into the equation. The current bunch of CAA surveyors seem to have no idea about the GA side of the industry. The licensed engineers with years of experience are being replaced by tick-box paperwork and accountable managers, quality insurance, schedules and the like - not very suitable for 2/3 man organisations. I was probably under the misapprehension that these kind of changes had to be cost justified; so where is the prove that these changes will improve quality or safety. I know that some owners feel in the past that the workmanship has not always up to standard but Part M does absolutely nothing to improve this.
This newly proposed individual maintenance schedule will do nothing more than the LAMP and the SB and AD research already accomplishes and just incur further expense for the owners because of the CAA involvement.

[Peter Gristwood]

I know that some owners feel in the past that the workmanship has not always up to standard but Part M does absolutely nothing to improve this.

Absolutely. It is a classic example of the use of quality assurance. EASA's paperwork trail is expensive and adds nothing to safety

It guarantees consistency so if the work is poor it will be consistently poor.

[peterh337]

those that in the past never maintained those standards will STILL NOT do the work

Exactly. The right boxes will be ticked though.

It guarantees consistency so if the work is poor it will be consistently poor.

Exactly, like the much bigger scam called ISO9000. Completely worthless nowadays.

But, this is the "European way".

[giloc]

Originally Posted by vee-tail-1

Whatever happens, for safety sake we should all be using the relevant type specific maintenance programmes for our aircraft.

That is complete nonsense. You might prefer to use a type specific MP for any number of reasons, but there is not a shred of evidence to suggest that it is safer to do so.

[jxk]

OWNERS

Why aren't OWNERS consulted about these proposed changes, after all the CAA are supposed to be the authority that is responsible for representing their interest with regard to safety and COSTS. If, for instance, you think of the CAA with regard to air passengers, their role seems to be to protect them from airline bankruptcy etc.
I think owners should be canvassed for their opinion as ultimately it's their resopnsiblity to ensure that their aircraft is maintained to a suitable standard.
It would nice to think that the CAA were there to HELP not HINDER.

[NutLoose]

Get your comments in, it is a consultation until next month, the more comments they get may make a difference, that is why I mentioned it, it wasn't exactly publisiced much.

[vee-tail-1]

That is complete nonsense. You might prefer to use a type specific MP for any number of reasons, but there is not a shred of evidence to suggest that it is safer to do so.

Oh dear, I wonder just how safe a BMW might be if the garage used a Morris Minor maintenance manual to service it.

How many "Gotchahs!" do you think are being missed by maintenance organisations using LAMP and working on an unfamiliar type? I can think of two safety critical tasks that are not addressed by LAMS, or LAMP, on my simple aircraft. The number on a modern complex type must be considerable.
Just because no one has yet died due to LAMP does not make it or any generic programmes safe or even fit for purpose.

[NutLoose]

LAMS and lamp were never intended to be a be all and end all maintenance programme, simply a basis to build upon.

[peterh337]

Silvaire1 above is right. The FAA system works.

Unfortunately here in Europe we have 2 issues.

First is the background of the people behind EASA. Eric Sivel comes from a certification background (a friend of mine has various ancient certificates on the wall, from aviation courses, with Sivel's signature on the bottom) and people from that background will always be out to generate documented processes. And once you embark on that, there is no end to it. Documentation will never be perfect, which makes it a great job to be in - so long as the layer of management above you is stupid enough to keep funding you. The "stupid enough" requirement is amply met in the EU ruling class (where nobody above the rank of Sivel and his cronies understands aviation) and it is usually met in business which is why ISO9000 is such a notorious "QA Dept empire building" scam which is nothing to do with quality.

The other is that crap maintenance is a feature of a significant % of accidents, and then it comes down to the debate of how much control the State should have over the individual's attitude to risk. In the USA the answer is "little". In Europe the answer is "lots".

And unfortunately the maintenance business plays into EASA's hands, by taking whatever schedule they have (LAMP, the manufacturers's full schedule, whatever), rubber stamping all the way down the page, but actually (in most cases) doing only some of it.

My aircraft has a very long mfg schedule which almost nobody follows - unless you ask for it, and then the price of the Annual doubles. And much of it is pointless. But a lot of it is essential, like dismantling bearings and greasing them... most maintenance shops just squirt some aerosol lube in there and the customer is happy because everything feels nice and smooth. He doesn't know the abrasive crap is still in there and years down the road he will get a huge bill for a new bearing, which in this ripoff game is usually a complete new airframe part because there is no CMM for replacing just the bush. I work this to my satisfaction by knowing what needs to be done and making sure it is done (I drop in during the Annual, and inspect everything before the inspection covers go back on) but most owners do not have that level of expertise so they get shafted with much expensive work when the chickens come home to roost in later years.

There will never be a good solution to this, because aircraft can be maintained to varying degrees and all of them work and are safe provided a small number of essential tasks are done (like magneto inspections or overhauls) and the work is done by somebody competent.