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Owner-pilot maintenance of RA-Aus aircraft


Rev. 5 — updated 1 December 2014
  
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In the Sport and Recreational Aviation context 'maintenance' means any task required to ensure — or that could affect — the continuing airworthiness of an aircraft, including any one or combination of inspection, adjustment, preservation, overhaul, repair and defect rectification. It includes replacement of materials, parts or the components of an 'aeronautical product'.

Incorporation of manufacturer-specified modifications is included as a maintenance task but own design — or redesign — of modifications/alterations is not.

In General Aviation most aircraft maintenance and authentication must be performed by Licenced Aircraft Maintenance Engineers or other specialists although pilots entitled to do so may perform some maintenance/servicing tasks specified in Part 4A of the Civil Aviation regulations . The RA-Aus maintenance system differs in that owner-pilots may perform and authenticate the maintenance on their own aircraft, except any aircraft operated by a Flight Training Facility.




Contents

1. Accreditation of RA-Aus maintenance personnel

Aircraft conforming to and operated in accordance with the Civil Aviation Orders CAO 95.10, CAO 95.55 and CAO 95.32 are exempt from those Civil Aviation Regulations listed in the CAOs. The exemptions include CAR Part 4A Maintenance so RA-Aus assumes responsibility for specifying the maintenance requirements for aircraft registered with the administration organisation and thus, has responsibility for accrediting suitably qualified and experienced individuals to conduct maintenance on RA-Aus aircraft. See the Technical Manual maintenance policy.

Note that the 2007 Technical Manual section Accreditation of persons suitable to conduct maintenance currently states that RA-Aus pilots are automatically granted minimum qualification RA-Aus 'Level One Maintenance Authorities' but RA-Aus pilots are now no longer automatically granted RA-Aus Level One Maintenance Authorities with receipt of their Pilot Certificate.

Practically all pilots-in-training do not own an RA-Aus aircraft nor do 60% of RA-Aus pilot certificate holders and those non-owner pilots have no need for any maintenance authority qualification. It is probable that, during 2015, all RA-Aus aircraft owners who hold a current Pilot Certificate and who elect to maintain Level 1 maintenance accreditation will be required to complete a syllabus of competency-based training and some form of examination to demonstrate sufficient knowledge of the required tasks before being granted Level 1 maintenance accreditation under revised rules.

To facilitate maintenance, four levels of RA-Aus Maintenance Authority certification are available to members:
  • Level 1 Maintenance Authority: aircraft owners must undertake a qualification test before performing the maintenance tasks for which they are judged competent and also to authenticate in the aircraft logbook the maintenance performed. They are qualified only on their own aircraft, provided the aircraft is not used for hire-and-reward e.g. flight training — or for glider towing. If the owner is not competent to perform a particular task and chooses not to undertake the necessary training, then that task should be assigned to a suitable Level 2 (or higher) holder or done under the supervision of the Level 2. If an owner-pilot does not choose to do any maintenance then level 1 qualification is not necessary and the owner must arrange for a competent Level 2 (or higher) person to perform and authenticate all maintenance, including the daily inspection.

    The trial online L1 Maintainer Authority Training and Assessment package comprises:

    • A Study Guide to lead trainees through a series of questions and answers designed to provide them with a sound understanding of the privileges and responsibilities as an L1 maintenance authority holder.
    • A range of reference materials are provided by way of links. Aircraft must be inspected and maintained in accordance with aircraft manufacturers' manuals. In some cases aircraft do not have such manuals, these aircraft must be inspected and maintained in accordance with acceptable aviation maintenance methods and practices. The FAA have produced a range of documents which provide guidance as to what are considered to be acceptable methods and practices. A link to this publication is also provided in the study guide.
    • Assessment - when prospective L1s feel confident about their ability to answer questions about maintaining their aircraft, they may sit the online assessment. The assessment is an open book, 50 question, multi-choice examination with a time allowance of 3.5 hours requiring a score of 40/50 to achieve a pass.

  • Level 2 Maintenance Authority: for suitable persons to conduct paid maintenance on owner-pilot aircraft or conduct and/or authenticate maintenance on aircraft used for hire, flight training and glider towing. Level 2s may have restrictions related to aircraft or engine type.

    Level 2 accreditation is awarded on the basis of qualifications and experience of each applicant, is valid for two years and only while the holder remains a financial RA-Aus member. See the current list of about 400 accredited L2 maintenance persons.

    Restricted Level 2 accreditations are deemed to be able to perform line maintenance on training aircraft or aircraft used for hire-and-reward, unless as otherwise defined by the RA-Aus Technical Manager. Note that those defined line maintenance items are much the same as the list of maintenance that may be carried out on a General Aviation Class B aircraft by a pilot entitled to do so under CAR 42ZC / CAAP 42ZC-1(2) but be aware that CAR 42ZC is part of CAR 1988 Part 4A and thus is not applicable to RA-Aus pilots.

  • Level 3 Maintenance Authority: for about 20 suitable persons to act as regional supervisors, coordinators and points of contact for maintenance activities. The RA-Aus Technical Manager appoints Regional Technical Officers [RTOs] when suitable persons are available. The duties of the RTO include assistance to the Technical Manager in conducting Level 2 maintenance checks on aircraft used in flight school operations, as requested by the Technical Manager. See the current list of all accredited Level 3: Regional Technical Officers.

  • Level 4 Maintenance Authority: for suitable and accredited persons to act as Amateur Built Inspectors in addition to performing the same tasks as defined at Level 2. RA-Aus certificates for the purposes of an Amateur Built Inspector rating are issued on receipt of the appropriate requirements. To be eligible for an Amateur Built Inspector approval, the applicant will generally be a CASA Licenced Aircraft Maintenance Engineer [LAME] in engines or airframes and be a financial member of RA-Aus. See the current list of about 80 accredited Amateur Built Inspectors.


2. Maintenance authentication

The elements of maintenance are what to do, when to do it and how to do it.

Maintenance authentication is the action of a suitably qualified person annotating the aircraft maintenance log book underneath the listing of all maintenance carried out at that time and formally indicating that the work conducted is to the standard specified in the RA-Aus Technical Manual. The authentication is made by signing the aircraft maintenance log book, printing name and initials, RA-Aus membership number, aircraft/engine hours and the date.

The authentication act is equivalent to signing a maintenance release (i.e. releasing the aircraft for normal flying operations or certifying that the aircraft is fit to fly) even though in most cases the aircraft owner is both the accedited maintainer and the pilot. This can constitute quite a character challenge — and test of responsibility and discipline — when the pilot personality is itching to go and the maintenance technician personality knows there are a few minor things that need attention.

The daily inspection [DI], before the start of flying operations on each day that the aircraft is to be flown, may be completed by the owner-pilot with an L1 maintenance authority or the holder of an L2 authority. A log book authentication is required.

Where there is a group-owned aircraft one owner must be appointed to be responsible for — and control of — all maintenance on that aircraft. That one person is to list in the log book all maintenance carried out and sign-off the authentication.


3. RA-Aus maintenance policy

Owner-operated aircraft
Maintenance to owner-operated RA-Aus aircraft is the sole responsibility of the owner(s).

The selection of appropriate maintenance schedules and the qualifications and experience of persons to complete the maintenance on the non-LSA privately-built and amateur-built categories in CAO 95.10 and CAO 95.55, is the responsibility of the owner.

Maintenance conducted on the factory-built and the LSA kit-built aircraft categories in CAO 95.32 and CAO 95.55, shall be in accordance with the manufacturers' maintenance/service manuals and schedules including all supplementary service instructions, service letters and service bulletins issued from time-to-time.

Where such a schedule does not exist or a copy cannot be obtained, the Technical Manual's 'Maintenance schedules and periodic inspections' document must be followed.

The U.S. Federal Aviation Administration produced a substantial 613 page A4 size advisory circular AC 43.13-1B titled 'Acceptable methods, techniques and practices — aircraft inspection and repair'. Such methods are acceptable when there are no manufacturer repair or maintenance instructions. The AC generally applies to relatively minor repairs. A PDF version of the book is included in the RA-Aus Members' CD or a hard copy may be purchased from the RA-Aus shop. For an example of the contents the safetying section of AC 43.13-1B is available in html format in the 'Builders guide to safe aircraft materials'.

Note: an example of a manufacturer's service manual can be downloaded from the Jabiru website. Scroll down the left-hand frame of their home page, click 'Manuals' then scroll down to 'Aircraft technical manuals' and click 'J160 J170' — it is a 15 MB pdf file.
Aircraft used for hire-and-reward
Only factory-produced aircraft may be offered for hire-and-reward; i.e. flight training — other than the CAO 95.55 para 1.5 aircraft used for flight training of the aircraft builder or builders. Aircraft used for hire-and-reward are to be wholly maintained, and/or the maintenance authenticated by, a Level 2 Maintenance Authority holder. Daily inspections may be completed by the pilot-in-command.

A solo check flight after scheduled maintenance in accordance with the manufacturer's schedule is mandatory before the aircraft is used for hire-and-reward. Successful completion of this check flight is to be recorded in the aircraft log book and signed for by the Level 2 accredited person who conducted the technical work and the pilot who conducted the flight.

Engine controls, engine accessories, propellers and flight controls are regarded as critical maintenance items and should be checked by an independent person after any maintenance. This applies to both owner-operated aircraft and hire-and-reward aircraft.
Aircraft used for glider towing
An aircraft used for glider towing has to be both certified for glider towing by the manufacturer and accepted by the Gliding Federation of Australia [GFA]. The GFA also approves the pilot, even if they have an RA-Aus glider towing endorsement. Maintenance must be carried out by a Level 2 accredited person, in accordance with the manufacturer's glider towing supplement, or a GFA approved maintenance scheme or one approved by the RA-Aus Technical Manager.


4. Technical Manual issue 3 maintenance section

Maintenance section contents:

4.0 Policy
        Annex A Maintenance tasks and authorities required

4.1 Accreditation of persons to conduct maintenance on recreational aircraft
4.1.1 Criteria for assessment of RA-Aus Level 2 Maintenance Authorities
        Annex A maintenance supervisor questionnaire (attached to the 4.1.1 document)
        Annex B Definition of line maintenance

4.2 Inspection of recreational aircraft
4.2.1 Daily and pre-flight Inspections
4.2.2 Inspection after assembly
4.2.3 Inspection after heavy landing
4.2.4 Periodic inspections
        Annex A Maintenance schedules and periodic inspections (attached to the 4.2.4 document)
4.2.5 Piston engine continuing airworthiness requirements
        Appendix A four-stroke piston engine condition check (attached to the section 4.2.5 document)
        Annex A four-stroke piston engine cylinder leak check
        Annex B four-stroke piston engine condition report
        Annex C two-stroke piston engine check [not yet finalised]

4.3 Defect reporting and airworthiness notices
        Annex A: Aircraft defect report (attached to the section 4.3 document)
        Annex B: Aircraft airworthiness notice (attached to the section 4.3 document)

4.4 Repairs

4.5 Log books and other records



5. The 2008 FAA Aviation Maintenance Technician Handbook

Recrational aircraft owners or potential owners may find portions of this handbook informative.

"The Aviation Maintenance Technician Handbook – General was developed as one of a series of three handbooks for persons preparing for mechanic certification with airframe or powerplant ratings, or both. It is intended that this handbook will provide basic information on principles, fundamentals, and technical procedures in the subject matter areas common to both the airframe and powerplant ratings. Emphasis in this volume is on theory and methods of application. The handbook is designed to aid students enrolled in a formal course of instruction preparing for FAA certification as a maintenance technician, as well as for current technicians who wish to improve their knowledge. This volume contains information on mathematics, aircraft drawings, weight and balance, aircraft materials, processes and tools, physics, electricity, inspection, ground operations, and FAA regulations governing the certification and work of maintenance technicians. New to this volume is a section addressing how successful aviation maintenance technicians incorporate knowledge and awareness of ethics, professionalism, and human factors in the field."

Note: the chapters are contained in large PDF files.



The FAA advisory circular AC 43.13-1B 'Acceptable methods, techniques, and practices — aircraft inspection and repair' (~ 650 pages and incorporating the 2001 changes) is available from the RA-Aus online shop for about $50. It is bound together with the FAA advisory circular AC 43.13-2A 'Acceptable methods, techniques, and practices — aircraft alterations' (~ 100 pages). Some of the information in this book — manufacturer's part numbers for example — may be out of date.


The next module in this 'Joining sport and recreational aviation' series discusses the legislative framework that enables Australian sport and recreational aviation




The 'Joining sport and recreational aviation' series

Compiled © 2009-2014 by John Brandon     [contact information]