MEL procedures
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MEL procedures
Hi,
Does anybody know any authorized by JAA Authority MEL procedure for AOC holder which would accept that pilot him/herself determines an inoperative equipment, put the note to Tech Log, check it against the MEL and then defer it accordingly?
Or does the last part have to be performed by qualified maintenance personnel (I mean mechanics or engineers) only?
Particularly, I am talking about situations when we discover failure during flight than land at airport where we dont have maintenance personnel. If we make a note to Tech Log, we need to wait for Maintenance people to come, inspect it and defer it. That costs a lot of time and money.
Is there a way to authorize pilot to make those defect deferral according to MEL?
Does anybody know any authorized by JAA Authority MEL procedure for AOC holder which would accept that pilot him/herself determines an inoperative equipment, put the note to Tech Log, check it against the MEL and then defer it accordingly?
Or does the last part have to be performed by qualified maintenance personnel (I mean mechanics or engineers) only?
Particularly, I am talking about situations when we discover failure during flight than land at airport where we dont have maintenance personnel. If we make a note to Tech Log, we need to wait for Maintenance people to come, inspect it and defer it. That costs a lot of time and money.
Is there a way to authorize pilot to make those defect deferral according to MEL?
Nemo Me Impune Lacessit
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Once you have shut down and entered the defect in the Tech Log I think you will find that it requires a licensed engineer to defer it and sign off the Tech Log. By contacting home base, talking to engineers etc. it may be possible to continue to base with a covering telex from the engineers.
If the defect doesn't effect flight safety then don't enter it until the final shut down, hopefully at a place with engineering support, but always bear in mind that a pilot may mis identify a defect as the primary problem when, in fact, it is only a result of something much more serious.
If the defect doesn't effect flight safety then don't enter it until the final shut down, hopefully at a place with engineering support, but always bear in mind that a pilot may mis identify a defect as the primary problem when, in fact, it is only a result of something much more serious.
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Depends on your local Regulatory requirements and the company's QA procedures.
It is quite common (especially for non-sked ops) to have pilots authorised to do simple maintenance, or to certify for the completion provided a bunch of relevant things have been done.
The airline folk generally don't have a need to worry about this sort of thing in comparison.
If the defect doesn't effect flight safety then don't enter it until the final shut down
I wouldn't want to get caught out - could be embarrassing at the Enquiry if a mishap can be related to the action.
always bear in mind that a pilot may mis identify a defect as the primary problem when, in fact, it is only a result of something much more serious
of course that is a consideration. The folks who use these sorts of procedures constrain what the pilot can/can't do and the pilot generally isn't acting alone - rather, he/she is effecting an administrative function in the main.
It is quite common (especially for non-sked ops) to have pilots authorised to do simple maintenance, or to certify for the completion provided a bunch of relevant things have been done.
The airline folk generally don't have a need to worry about this sort of thing in comparison.
If the defect doesn't effect flight safety then don't enter it until the final shut down
I wouldn't want to get caught out - could be embarrassing at the Enquiry if a mishap can be related to the action.
always bear in mind that a pilot may mis identify a defect as the primary problem when, in fact, it is only a result of something much more serious
of course that is a consideration. The folks who use these sorts of procedures constrain what the pilot can/can't do and the pilot generally isn't acting alone - rather, he/she is effecting an administrative function in the main.
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MEL
You need to discuss this issue with your Chief Pilot and/or your Chief Engineer. You may well be able to be authorised to operate under the MEL, or alternatively you may be able to be given an authority to operate outside the MEL by being granted a "Dispensation" provided no flight safety issue is involved. In any event, even if the MEL covers the defect it is the PIC who determines whether or not to accept the Deferred Defect.
FAA MELs have these statements (B717 MMEL):
Here in Australia, our company ops manual authorises the Captain to defer a defect provided there is no (M) action required. You obviously have to comply with the Operations (O) requirements.
Additionally, some items in our MEL are called "FCM", which means Flight Crew Maintenance. In this case, the captain is authorised to defer the defect after doing the FCM.
Example: Gasper fan U/S
15. "(M)" symbol indicates a requirement for a specific maintenance procedure which must be accomplished prior to operation with the listed item inoperative. Normally these procedures are accomplished by maintenance personnel; however, other personnel may be qualified and authorized to perform certain functions. Procedures requiring specialized knowledge or skill, or requiring the use of tools or test equipment should be accomplished by maintenance personnel. The satisfactory accomplishment of all maintenance procedures, regardless of who performs them, is the responsibility of the operator.
Appropriate procedures are required to be published as part of the operator's manual or MEL.
16. "(O)" symbol indicates a requirement for a specific operations procedure which must be accomplished in planning for and/or operating with the listed item inoperative. Normally these procedures are accomplished by the flight crew; however, other personnel may be qualified and authorized to perform certain functions. The satisfactory accomplishment of all procedures, regardless of who performs them, is the responsibility of the operator. Appropriate procedures are required to be published as a part of the operator's manual or MEL.
NOTE: The (M) and (O) symbols are required in the operator's MEL unless otherwise authorized by the Administrator.
Appropriate procedures are required to be published as part of the operator's manual or MEL.
16. "(O)" symbol indicates a requirement for a specific operations procedure which must be accomplished in planning for and/or operating with the listed item inoperative. Normally these procedures are accomplished by the flight crew; however, other personnel may be qualified and authorized to perform certain functions. The satisfactory accomplishment of all procedures, regardless of who performs them, is the responsibility of the operator. Appropriate procedures are required to be published as a part of the operator's manual or MEL.
NOTE: The (M) and (O) symbols are required in the operator's MEL unless otherwise authorized by the Administrator.
Additionally, some items in our MEL are called "FCM", which means Flight Crew Maintenance. In this case, the captain is authorised to defer the defect after doing the FCM.
Example: Gasper fan U/S
MAINTENANCE (M) (FCM)
Pull and collar the associated Gasper Fan circuit breakers, as follows:
GASPER BOOSTER FAN (B1-1170) EPC CBP J-27
GASPER BOOSTER FAN CONTROL (B1-1171) EPC CBP C-3
Pull and collar the associated Gasper Fan circuit breakers, as follows:
GASPER BOOSTER FAN (B1-1170) EPC CBP J-27
GASPER BOOSTER FAN CONTROL (B1-1171) EPC CBP C-3
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More Tech Log than MEL - You Need EASA Part M M.A.403
MEL is governed by EU Ops 1.085 when talking Flight Crew..........
The Commander shall: decide whether or not to accept an aeroplane with unserviceabilities allowed by the CDL or MEL.
So.....
As part of applying for an AOC an Operator will get approval to EASA Part M. Part of the Approval process is to submit a CAME ( Continuing Airworthiness Management Exposition). In the CAME will be the process of who and when certain actions can take place OUTSIDE of Part 145 which satisfy EASA Part M M.A.403
Maintenance. M.A.403 Aircraft defects
(a) Any aircraft defect that hazards seriously the flight safety shall be rectified before
further flight.
(b) Only the authorised certifying staff, according to points M.A.801(b)1, M.A.801(b)2,
M.A.801(c), M.A.801(d) or Annex II (Part-145) can decide, using M.A.401 maintenance
data, whether an aircraft defect hazards seriously the flight safety and therefore
decide when and which rectification action shall be taken before further flight and
which defect rectification can be deferred. However, this does not apply when:
1. the approved minimum equipment list as mandated by the competent authority is used by the pilot;
or,
2. aircraft defects are defined as being acceptable by the competent authority.
(c) Any aircraft defect that would not hazard seriously the flight safety shall be rectified
as soon as practicable, after the date the aircraft defect was first identified and within
any limits specified in the maintenance data.
The Commander shall: decide whether or not to accept an aeroplane with unserviceabilities allowed by the CDL or MEL.
So.....
As part of applying for an AOC an Operator will get approval to EASA Part M. Part of the Approval process is to submit a CAME ( Continuing Airworthiness Management Exposition). In the CAME will be the process of who and when certain actions can take place OUTSIDE of Part 145 which satisfy EASA Part M M.A.403
Maintenance. M.A.403 Aircraft defects
(a) Any aircraft defect that hazards seriously the flight safety shall be rectified before
further flight.
(b) Only the authorised certifying staff, according to points M.A.801(b)1, M.A.801(b)2,
M.A.801(c), M.A.801(d) or Annex II (Part-145) can decide, using M.A.401 maintenance
data, whether an aircraft defect hazards seriously the flight safety and therefore
decide when and which rectification action shall be taken before further flight and
which defect rectification can be deferred. However, this does not apply when:
1. the approved minimum equipment list as mandated by the competent authority is used by the pilot;
or,2. aircraft defects are defined as being acceptable by the competent authority.
(c) Any aircraft defect that would not hazard seriously the flight safety shall be rectified
as soon as practicable, after the date the aircraft defect was first identified and within
any limits specified in the maintenance data.
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Diesel 10 has it correct. The whole point of an MEL is to allow an aircraft to continue for a period of time (the rectification interval) with an allowable defect. The pilot writes the defect in the Tech Log and if it is deferable as per the MEL transfers the defect to the ADD list. This way he is "clearing" the defect from the technical log. Part M realy is good for operators but one must realy read and understand it.
All EASA operators must have a Part M approval. Some small operators subcontract the Part M responsbilities to a 145 maintenance contractor. This is a bad idea because the maintenance contractor can insist that a defered defect can only be cleared by them. (good business for the maintenance contractor) Some 145 contractors still insist that they are the only people who can defer defects and I think this is a throw back to pre EASA when a contracted maintenance provider was responsible for your maintenance. Of course, he does not have that responsibility any more but some still think they do.
All EASA operators must have a Part M approval. Some small operators subcontract the Part M responsbilities to a 145 maintenance contractor. This is a bad idea because the maintenance contractor can insist that a defered defect can only be cleared by them. (good business for the maintenance contractor) Some 145 contractors still insist that they are the only people who can defer defects and I think this is a throw back to pre EASA when a contracted maintenance provider was responsible for your maintenance. Of course, he does not have that responsibility any more but some still think they do.
