Maintenance and ARC
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Maintenance and ARC
Although myself wallowing in the morass of Part M etc,decisions and amendments,I thought that it would be straightforward for a maintenance organization to carry out work to the new 'Maintenance Inspection Programme' and accept the self declared maintenance program, on the standard CAA published form,.all as EASA 2015/1088.
However I have found that the maintenance organizations I have contacted are not only unwilling to accept the self declaration but will not implement the MIP. They also say they have never seen the documentation of self declaration or the MIP
Have I just been unfortunate or is there an industry wide refusal to accept these changes?
However I have found that the maintenance organizations I have contacted are not only unwilling to accept the self declaration but will not implement the MIP. They also say they have never seen the documentation of self declaration or the MIP
Have I just been unfortunate or is there an industry wide refusal to accept these changes?
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atceng, what type are you flying? I ask because as I understand it the MIP (Minimum Inspection Programme) is at present only available for ELA 1 aircraft. MIP for ELA 2 types (and beyond) is on its way but not yet delivered.
But the fly in the ointment might be that Part M organisations may have to apply for additional privileges in order to carry out the Airworthiness Review at the same time as the annual inspection, a requirement of the MIP, and that will probably entail additional expenditure and fuss for the organisation. It also implies that the ensuing ARC will be an annual 'uncontrolled' ARC instead of a 'controlled' 3 yearly ARC.
Which brings me round to my original question. What do you fly and how is it presently maintained? My own machine is ELA 1 and I operate with an 'uncontrolled' ARC using the BGA as CAMO. That means that I can do my own maintenance and have it signed off by a BGA inspector. In theory I believe you are able to do exactly the same thing with any Part M organisation but the trick would be in getting that organisation to accept that you are competent to do the work and to be prepared to sign it off afterwards.
So it probably comes down to a purely commercial decision for the CAMO. More expense but less income and arguably little reduction in responsibility.
But the fly in the ointment might be that Part M organisations may have to apply for additional privileges in order to carry out the Airworthiness Review at the same time as the annual inspection, a requirement of the MIP, and that will probably entail additional expenditure and fuss for the organisation. It also implies that the ensuing ARC will be an annual 'uncontrolled' ARC instead of a 'controlled' 3 yearly ARC.
Which brings me round to my original question. What do you fly and how is it presently maintained? My own machine is ELA 1 and I operate with an 'uncontrolled' ARC using the BGA as CAMO. That means that I can do my own maintenance and have it signed off by a BGA inspector. In theory I believe you are able to do exactly the same thing with any Part M organisation but the trick would be in getting that organisation to accept that you are competent to do the work and to be prepared to sign it off afterwards.
So it probably comes down to a purely commercial decision for the CAMO. More expense but less income and arguably little reduction in responsibility.
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Ask yourself this, why should a guy work very hard to get an engineering licence and then let some unskilled person work on an aircraft ( reducing his income ) and then sign the work off, this exposes him to the risk that if something goes wrong the lawyers will come after him.
I know that you are all going to say that the engineer should only sign for what he has seen but the leagal profession will cloud the issue and insist that while an engineer has been called to inspect the engine he should have exercised his duty of care and seen the rudder hinge was about to fail.
No wonder the engineering company's want nothing to do with it !
I know that you are all going to say that the engineer should only sign for what he has seen but the leagal profession will cloud the issue and insist that while an engineer has been called to inspect the engine he should have exercised his duty of care and seen the rudder hinge was about to fail.
No wonder the engineering company's want nothing to do with it !
My ELA1 aircraft is on uncontrolled Part M. I looked at going over to controlled but frankly there was no difference in cost and I had to hand over responsibility to the maintenance company and pay them to do my log books, which for five hours a month seemed a little over the top. Even they agreed that as I work closely with them at all times and liaise on all matters there would be no great benefit for me.
When I said that I also wanted to stay uncontrolled to take advantage of Part M (Light) they said that they would be reluctant to get involved with any part of it until all requirements were cast in stone and not liable to be changed at the whim of EASA or the CAA. Their viewpoint was that on previous occasions they had spent time and money gearing up for regulation change only to find the goal posts moved after they had complied with initial drafts and rulings etc.
I hope there will be some relief for us on full Part M in the future but frankly unless you want to ask the CAA to approve your LAMP and work alone, then companies are unlikely to be enthusiastic about implamenting change. As A&C say's, it's a bit like asking a Turkey to sign your Christmas cards!
When I said that I also wanted to stay uncontrolled to take advantage of Part M (Light) they said that they would be reluctant to get involved with any part of it until all requirements were cast in stone and not liable to be changed at the whim of EASA or the CAA. Their viewpoint was that on previous occasions they had spent time and money gearing up for regulation change only to find the goal posts moved after they had complied with initial drafts and rulings etc.
I hope there will be some relief for us on full Part M in the future but frankly unless you want to ask the CAA to approve your LAMP and work alone, then companies are unlikely to be enthusiastic about implamenting change. As A&C say's, it's a bit like asking a Turkey to sign your Christmas cards!
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I thank contributors for their inputs,they will all help to clarify the situation.
Under the new regs the listed tasks which the owner operator is allowed to undertake now do not need a release to service by a licensed engineer but can be signed off by the owner operator who must be a pilot qualified to fly the aircraft.
The owner operator is cautioned that they must be sure that they have the necessary skills, tools, and experience. Checks such as 50hr oil change,filter cleaning/replacement are within the scope of the ownop.
This means that engineers will not be asked to certify work carried out by others,which I fully appreciate they dont want to do for many obvious reasons.
Anything concerning flight controls are explicitly excluded,as are many other flight critical items,mags etc. and only the listed tasks can be performed.
Possibly the CAA are obliquely addressing the present and future shortage of qualified engineers by releasing them from non critical work in order to concentrate on essential work on transport and training aircraft.
Maintenance facilities in the UK seem to be vastly overstretched. When asked if they can undertake a repair say next month there is a sharp intake of breath and head shaking,followed by a long list of committments.
On a quick look through GA mags I found no advertisements for Part 145 facilities.
Adoption by the industry would result in more pilots electing for CAA aircraft due to much reduced costs,and probably more business not less,and more pilots flying well proven aircraft.
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Under the new regs the listed tasks which the owner operator is allowed to undertake now do not need a release to service by a licensed engineer but can be signed off by the owner operator who must be a pilot qualified to fly the aircraft.
The owner operator is cautioned that they must be sure that they have the necessary skills, tools, and experience. Checks such as 50hr oil change,filter cleaning/replacement are within the scope of the ownop.
This means that engineers will not be asked to certify work carried out by others,which I fully appreciate they dont want to do for many obvious reasons.
Anything concerning flight controls are explicitly excluded,as are many other flight critical items,mags etc. and only the listed tasks can be performed.
Possibly the CAA are obliquely addressing the present and future shortage of qualified engineers by releasing them from non critical work in order to concentrate on essential work on transport and training aircraft.
Maintenance facilities in the UK seem to be vastly overstretched. When asked if they can undertake a repair say next month there is a sharp intake of breath and head shaking,followed by a long list of committments.
On a quick look through GA mags I found no advertisements for Part 145 facilities.
Adoption by the industry would result in more pilots electing for CAA aircraft due to much reduced costs,and probably more business not less,and more pilots flying well proven aircraft.
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atceng
REF
They also say they have never seen the documentation of self declaration or the MIP.
In which case sounds like this maintenance company are not up to date with the documentation the CAA send out.. Or they have decided to ignore it..
REF
They also say they have never seen the documentation of self declaration or the MIP.
In which case sounds like this maintenance company are not up to date with the documentation the CAA send out.. Or they have decided to ignore it..
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I think that at the moment the Part 145 orgs have two major concerns.
1)Implementing the MIP would reduce revenue by 80%
2)The maintenance procedure structure probably requires new documentation ,and accreditations which cost time and money.
In view of the overcommittment of most Part 145 orgs. they could perform annuals in a fraction of the time it takes for LAMP and leave competent pilot/owners to do 50hr etc.
This would help reduce the workload to a sustainable level, but increase revenue due to increased throughput.
Oversight or releases of permitted work not being required they are relieved of responsibility for the p/o work,and worries signing off work they have little control over.
1)Implementing the MIP would reduce revenue by 80%
2)The maintenance procedure structure probably requires new documentation ,and accreditations which cost time and money.
In view of the overcommittment of most Part 145 orgs. they could perform annuals in a fraction of the time it takes for LAMP and leave competent pilot/owners to do 50hr etc.
This would help reduce the workload to a sustainable level, but increase revenue due to increased throughput.
Oversight or releases of permitted work not being required they are relieved of responsibility for the p/o work,and worries signing off work they have little control over.
