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.

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!

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.

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?

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......

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.

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.

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?

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.

Thanks vee-tail

The only thing I have is the CAMO contract. Will look deeper.

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

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

No good asking them - they gave us LAMP. :hmm:

Now we'll get a GMP - I bet its just LAMS section 9,10 & 11 of old tacked back on again! That made it more easa compliant than LAMP ever will be!

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.

Wow
 

There was me thinking it was the end of Linux, Apache, MySQL & PHP

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.

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.

Powerlimited
 

The latest is that LAMP as a whole has been found EASA non-compliant and so has to be replaced with a new maintenance program.

Which is where we came in....

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!!!!!!

giloc,

Thanks for the info.
As an aircraft owner myself, it means more unjustifiable costs and paperwork for yet another no-gain in safety or effeciency.
As a maintenance facility owner, it means more unjustifiable costs and paperwork for yet another no gain in safety or effeciency, coupled with another EASA reason for owners to whinge at increased costs. Problem is, it is easier for them to whinge at me than the source of the problem. Some days I just love my work.

I received a response from my surveyor advising me that LAMP was under review, but he wasn't aware of any decisions yet.

camlobe

You can. Or you can just look at them for condition. Or you can pointlessly replace them -the choice is yours, just write it in your LAMP.

Because no-one has been bothering to do that, thats perhaps one reason why the LAMP is found not sufficiently easa compliant??.

If the CAA have been requiring you to comply with regulations which were not lawful or unapproved then it seems to me you have a case for claiming compensation as the CAA must have been acting outside their authority. Perhaps soemting for the likes of AOPA to take up?

If it is a mandatory life limit you have to comply with it.....

I queried this and was told at the time by my surveyor that you would have a hard time getting a lifed item extended through the CAA against the Type Cert holders requirements.

Suggest you read this and look at the flow chart at the bottom..

http://www.caa.co.uk/docs/33/2011062...mentOfLAMP.pdf


Also shows how Lamp will become GMP... think's they have missed the I out of that acronym.... :E

To fully comply with current situation you have to fill in the worksheets for the airframe and the engine as laid out in the maintenance manual servicing section and also fill in LAMP.
Compiling a maintenance programme whilst time consuming will reduce the amount of time the CAMO will have to spend filling in paperwork. Also most radio manufacturers do not have any continuing airworthiness requirements which means you can take the radio check out of the annual check.
Also what you have to remember is that most manufacturers are !!!! at updating manuals and issue service bulletins instead and these all need to be addressed and if recurring included in the maintenance programme.

Cessna do not make the law, no matter what they might like to think. Even if they say its MANDATORY to eat 8 Jaffa Cakes prior to flight you dont need to, but you can if you want to.


Airworthiness Directives - mandatory - add to LAMP
Airworthiness Limitations - mandatory - add to LAMP


Cessna/Piper whoever is the TC holder recommendations - not mandatory - evaluate and add to LAMP as required or desired. Even says EVALUATE in that flowchart I just re-read.

Ask your surveyor again & get his reply in writing.

As for GMP, youre right! We'll be back to the GPMS of many years ago yet!

So where do you get the mandatory Airworthiness and life limitations from if they are not from the manufacturer?? and they are down as ADD ( ie mandatory )

I quote the Lamps Schedule

Section 3, Page 2
CAP 766 Light Aircraft Maintenance Programme – Aeroplanes

5 Airworthiness Life Limitations (Retirement/Scrap Lives)

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


Section 4

2 Permitted variations may not be applied to Airworthiness Directives, CAA Generic Requirements, airworthiness life limitations or
overhaul and test periods.

CAA / FAA/ EASA /....... Type Certificates Data Sheets

i.e. Stuff given out by the law-makers agencies.

But the Design Type Certificate is held by the manufacturer of the aircraft and LAMP clearly states theirs is the limits you have to adhere to, no one elses, and it's not evaluate, it is add.

The only way it is varied is as in the case of Engine TBO where the CAA issue a GRN to allow the TBO to be extended.

Somethings being lost in translation here.
Take the Cessna seat belt issue - lets say a 1977 Cessna 172.

The Cessna 172 Service manual states it is Cessna who have established the 10 year life. Not the FAA. Its therefore a TC holders recommendation and as such subject to evaluation for inclusion in LAMP just as your flowchart says.

There are no Airworthiness limitations or Life Limitations for a 1977 Cessna 172 either in the service manual or in the TCDS.

Take another for instance - American Champion 8KCAB Dekathlon.

This does have an Airworthiness Limitation in the Service Manual for the wing strut fittings being lifed at 1000 hours. However, without any FAA mandatedness it really means nothing & could be ignored as a manufacturers recommendation if desired, so the FAA include it in the TCDS to make it mandatory, and thus that one is required to be added to LAMP.

I think you (or your surveyor) are confusing CAA/FAA/EASA mandatedness with a manufacturer just saying mandatory to cover his backside.

In return for a manufacturer getting a Type Certificate, he effectively surrenders control of being able to vary future maintenance requirements, to the authority which issued that TC.

That is how aviation certification works.

That is why for example Cessna's "requirements" for some lifetime limit on some component are not mandatory (under Part 91). The FAA has the final say on that, instead.

And over decades the US aviation scene has developed in that way.

And it has worked very well. The manufacturers publish a list of stuff, but as it is not mandatory, they have not been exactly restrained in what they throw in.

The problem we have here in Europe is that the gravy train riders in EASA, and in the national CAAs before them, have been taking these manufacturer requirements at face value and enforcing them. The system was not designed to work that way, but these people are too dumb to understand, so they enforce life limits on stuff which has got no inherent degradation mechanism, or which is more likely to fail if messed with than if left alone.

There is a letter out there from the head of Socata, confirming that the only stuff which is mandatory under FAR Part 91 is what is in the Airworthiness section of the maintenance manual.

Actually Europe does not have a monopoly on money grabbing. Reading the US pilot forums, the practice of using disinformation is widespread over there too.

And that is the crux of what I was saying, like it or not you have to adhere to the life limits...... as they are the European governing body interpreting and laying down the requirements to replace them on the life limits.

Cessna 172 & Piper PA28 Owners
 

I would advise as a matter of urgency that owners who own these type of aircraft look at the 'consultation' document and voice their concerns with regard to proposed GMP which is due to close on the 16th March 2012. This yet another nail in the coffin for people that own this type of aircraft.
See http://www.caa.co.uk/docs/2263/20120...20Aircraft.pdf
and in particular the GMP Guidance

This document was dated 16/02/2012 consultation closes 16/03/2012 and was NOT sent to owners.

A little common sense has prevailed, at least for a while:

http://www.caa.co.uk/docs/33/Informa...ice2012062.pdf

Halleluiah! It must be the spring sunshine.
At last someone in the CAA must have seen that with EASA regulations, jumping last and avoiding gold plating is by far the best course ... :hmm:

Can we hope for a simple European permit system (like the LAA) for simple single engine light aircraft? :D