Airworthiness Notices and Directives - how do you stay informed?

[DonRamsay]

When we acquired our Tecnam Sierra P2002, I got onto the Tecnam website and subscribed to their AN/AD service. With that I am reliably informed (in both English and Italian ) of ADs.

 

Recently, I became aware that RA-Aus had put on their website a new "Airworthiness Alert" relating to Bowden Cable Bulkhead nuts (see attached). This is a "do it before next flight" kind of Notice so pretty serious stuff. While that one doesn't affect me personally, I wondered if the Notice would be seen by all the people who should act on the advice.

 

The fact is that, as the aircraft operator/owner (& builder?) we are responsible for making ourselves aware of this sort of stuff. While it is good to have a service like that provided by Tecnam and even the RA-Aus website, it is our responsibility to ourselves and our passengers - not to mention the people we fly over and our insurers - to make ourselves aware and act as required. If we don't do this then, apart from the human cost, we could find our insurance in danger, CASA on our case and even manslaughter charges by the Police.

 

Do we all feel we have this under control?

 

As a bit of a test of the information flow, Jabiru have made a major revision to their Maintenance Manual (May 2014). Amongst other things it makes it illegal for most owners to touch their Jab engines. There are various restrictions relating to factory training and L2/LAME status before you can take a spanner to a Jab engine.

 

Are Jab owners aware of this significant reduction of their rights to service and maintain their Jab engine?

 

I would not be surprised if many Jab owners, especially homebuilt Jab owners are unaware of or comply with this startling new requirement.

 

Bowden Cable bulkhead nuts bulletin 21072014.pdf

 

Bowden Cable bulkhead nuts bulletin 21072014.pdf

 

Bowden Cable bulkhead nuts bulletin 21072014.pdf

[Louie]

Whilst I agree aircraft owners/operators/builders need to take responsibility for being aware of these matters, surely RA-Aus has a fiduciary obligation to ensure prompt notification of any Airworthiness Notice to affected owners. The obvious one is emailing the appropriate people concerned according to information on the data base. Obviously this would not be possible at this stage for RA-Aus given recent issues, however at least an ability to subscribe to an email service for AD's and you can personally decide what is relevant to your situation. Failing all that, I would suggest checking the website everyday is not suitable or appropriate in this day and age.

 

With the current system imagine how many will carry on regardless and be oblivious to this control cable directive.

 

 

[Jaba-who]

The answer is to subscribe to all available services including CASA's AD service as well. You will get a lot of unnecessary ADs but you can fairly quickly delete the ones that don't apply to you.

 

 

[kgwilson]

With respect to the latest service bulletin on Bowden cable mandatory inspection RA-Aus would not have any idea what aircraft have Bowden cables and what don't in the 19 category. Unless people log into a forum such as this or the RA-Aus website & go looking for the bulletins they will not find out. Most pilots I know don't do either regularly & get most information by the aviation grapevine.

 

I agree that it would be a simple matter to email all owners of 19 registered aircraft with this bulletin or any other that required urgent attention but does everyone read their emails, do all members have an email address? I know of a number of pilots who do not have email. Nothing is as easy as it seems.

 

My kit supplier has always kept me up to date with any changes or issues, this being one of them and it is a service that is very much appreciated.

 

To answer Don's question (Even with the hints) No we certainly do not have this under control.

 

 

[DonRamsay]

do u mean this one Don?

Deborah, Yes, that could be it.

 

I have to admit that, while I'm aware of it, as I don't go too close to Jabiru engined aircraft, I haven't actually read it.

 

Is an RAA plane owner an authorized person?

No, the owner is not an authorised person unless (in Australia) they also happen to be a LAME and/or a L2 and I think there may even be a requirement to have done the factory course. The factory course on its own does not make you an "authorised person".

 

 

[Guest john]

I

 

Deborah, Yes, that could be it.I have to admit that, while I'm aware of it, as I don't go too close to Jabiru engined aircraft, I haven't actually read it.

No, the owner is not an authorised person unless (in Australia) they also happen to be a LAME and/or a L2 and I think there may even be a requirement to have done the factory course. The factory course on its own does not make you an "authorised person".[/quote

 

It very much looks like the days are now over for any Jabiru aircraft owner to maintain their own Jabiru engines as noted in the revised Jabiru maintenance procedures. Therefore RAA now has a duty to spell out loud & clear what maintenance if any a level 1 owner pilot can legally perform on their own Jabiru engine. Alternatively the CAR's provide specific maintenance procedures that a PPL holder can legally perform on their GA aircraft engine & airframe.

[DonRamsay]

Whilst I agree aircraft owners/operators/builders need to take responsibility for being aware of these matters, surely RA-Aus has a fiduciary obligation to ensure prompt notification of any Airworthiness Notice to affected owners. The obvious one is emailing the appropriate people concerned according to information on the data base.

The generalisation that "ignorance is no excuse in law" holds here as it does, well, generally.

 

Based on the Objects of RA-Aus, there may be an obligation for RA-Aus to inform its members but it is in no way a legal obligation. The legal obligation remains with us as PIC. Think of how CASA informs all pilots (GA & RA) of such things - put it on their website and hope somebody can be bothered looking and has the bloodhound instincts to find it.

 

I know our Tech Manager, Darren Barnfield, is looking to improve both the RA-Aus website and possibly sending out email notices but there are, believe it or not, still plenty of RA-Aus members who don't have an email address or don't have their current email address on file at RA-Aus.

 

. . . at least an ability to subscribe to an email service for AD's and you can personally decide what is relevant to your situation.

Sounds like a good idea to me. That gets around any privacy issues and thoughts of spam. I'll mention it to Darren and see what he thinks is possible. Perhaps what would be even better is a RSS service that lets us know if anything has changed on the RA-Aus website Ops or Tech or even financial or social.

 

. . . I would suggest checking the website everyday is not suitable or appropriate in this day and age.

Can't argue with that. So, each of us needs to solve that problem for ourselves. Easy for me with the Tecnam Bulletins, more difficult for others. However you do it, you owe it to yourself to do it.

 

With the current system imagine how many will carry on regardless and be oblivious to this control cable directive.

Unfortunately, while we might reach a quite a few RA-Aus pilots through this thread, there are still quite a few who will remain blissfully ignorant - at their peril.

 

And then there will others, particularly owner/builders who think, e.g. that Jabiru is being unreasonable and just covering their butts and ignore the new requirements. "I've maintained by Jab engine for 10 years, why should I hand it over to an L2 now?"

 

One thing that is very difficult to combat is ignorance, apathy and arrogance - particularly if it is all three together!

 

 

[coljones]

I

http://www.casa.gov.au/wcmswr/_assets/main/lib100178/maint-guide-pilots.pdf contains info on the Schedule 5 (daily inspection) and Schedule 8 (repairs) the can be carried out by a GA pilot.

 

 

[ave8rr]

If the Jab engine is bought and fitted to an aircraft a builder is building and registered "RAAus 19" then can they maintain that engine??

 

If Jab say NO then it wont be long before the owner of a Vans Experimental fitted with a Lycoming or Continental engine may find the same restriction will be placed on maintenance of these engines by the respective manufacturers.

 

 

[DonRamsay]

It very much looks like the days are now over for any Jabiru aircraft owner to maintain their own Jabiru engines as noted in the revised Jabiru maintenance procedures.

That is the bit I was referring to as "startling". I wonder if it will affect future sales of Jab engines for people who like to maintain the aircraft that they built? In the past you often hear of Jabiru blaming "improper maintenance" for premature engine failures. Looks like, to a casual observer, that Jabiru are trying to ban all amatuer mechanics from touching their engines. Wonder what excuse they could use then?

 

Therefore RAA now has a duty to spell out loud & clear what maintenance if any a level 1 owner pilot can legally perform on their own Jabiru engine. Alternatively the CAR's provide specific maintenance procedures that a PPL holder can legally perform on their GA aircraft engine & airframe.

The two authorities on this are the current (soon to be replaced) RA-Aus Tech Manual (Section 4.0 Annex A) and the aforementioned Jabiru Maintenance Manual. RA-Aus may allow more but is overruled by the manufacturer's maintenance manual.

 

 

[DonRamsay]

If the Jab engine is bought and fitted to an aircraft a builder is building and registered "RAAus 19" then can they maintain that engine??If Jab say NO then it wont be long before the owner of a Vans Experimental fitted with a Lycoming or Continental engine may find the same restriction will be placed on maintenance of these engines by the respective manufacturers.

Lycoming and Continental probably feel a bit more confident that their engines will not fail in service when provided normal care. Perhaps Jabiru actually believe their "improper maintenance" theory?

 

 

[coljones]

Lycoming and Continental probably feel a bit more confident that their engines will not fail in service when provided normal care. Perhaps Jabiru actually believe their "improper maintenance" theory?

Perhaps Lycoming and Continental have an expectation that their engines will be maintained by a LAME or AME under supervision or an L2 in RAA.

 

 

[DonRamsay]

Can't SAAA look after their Lycs and Contis if they build the aircraft?

 

 

[kgwilson]

I have just had a look at the May 2014 Jabiru Maintenance manual & the maintainer requirements have not changed from the July 2012 version It says:-

 

"6 Maintainer Requirements

 

 The following are recommended as the minimum requirements for someone carrying out maintenance & inspection on Jabiru Engines."

 

The detail below that is just the same. As far as I can see an owner/builder who has done the L1 course can still maintain his own engine. Jabiru just has a whole raft of recommendations that they have always had.

 

 

[Guest ozzie]

There have been several "Gear Alerts" issued by the APF in the recent past. These are issued to all members regardless of the equipment they use. They are issued via several methods. Mass emails to members, their website. several social media sites eg facebook etc, electronic and published newsletters. Word will travel fast these days if the effort is put in.

 

 

[frank marriott]

I have to admit that, while I'm aware of it, as I don't go too close to Jabiru engined aircraft, I haven't actually read it.

 

Maybe you should Don before making such a statement. Facts are good, BS is a waste of space.

 

 

[Oscar]

Lycoming and Continental probably feel a bit more confident that their engines will not fail in service when provided normal care. Perhaps Jabiru actually believe their "improper maintenance" theory?

Are you serious? Have you LOOKED at the 'exclusion of liability' clauses attached to ANY Textron communication? If Textron announced 'good morning', there would be three pages of legal qualification ensuring that such a statement was not legally binding and excluded application to [amongst other classes] any carbon-based lifeform ( currently in existence or otherwise) commencing with aardvarks and including up to - but not limited to the boundaries of - zooplankton.

 

 

[frank marriott]

Yes Deb

 

I have read it too, and I don't see the restriction as suggested by Don, but then he did say that he had not read it.

 

When you read it in total then, in my opinion at least, little has changed.

 

 

[frank marriott]

Whatever, I'm not up for a debate.

 

 

[Admin]

Previously we had them listed on this site however many of the ones listed on the RAAus site had broken links to docs and many other problems. I brought this to their attention however they simply replied with a basic it is not our responsibility statement. I then began to find the weekly CASA notifications also contained notices that were not being listed on the RAAus site and vice a versa...there wasn't any one place for notices that could be relied on especially when our lives lay in the balance. The ONLY solution to this is to continually monitor the website etc for the aircraft you fly and then, and only then, I believe, you will will be kept informed with reliable info.

 

I had a situation once where Flight Design announced an AD for my aircraft on their website and I had to bring it to RAAus attention. The Australian distributor even denied that the AD applied to any of their aircraft in Australia. I had a hell of a time proving to RAAus that my aircraft was affected by the AD including taking pictures and more...and this was a fully factory built aircraft. As I said, the only real source of accurate information is from the aircraft manufacturer...and then you can be assured, to the best degree, that you are covered

 

 

[jetjr]

SAAA members that have done the mantainers course and built their aircraft are aproved personsMe husband did the course and he is aproved

 

Problem solved for GA operators

Thought you now had to have a significant role in assembly of the engine you are maintaining?

 

 

[DonRamsay]

Maybe you should Don before making such a statement. Facts are good, BS is a waste of space.

OK Frank, I had relied on a reliable source who turns out to have been . . . reliable.

 

Anyone doubting my original post please have a look at the new manual section 2.2 where you will find the crystal clear direction from Jabiru regarding who can work on Jabiru engines. It as Deborah has quoted above. Perhaps the Jabiru Manual could have been better constructed so as not to leave any doubt?

 

No BS - just the facts. Ignore the direction from Jabiru as you wish and at your own risk.

 

Still, this Jabiru stuff is a side issue. The main game is that you need to know about the aircraft *you* fly. You need to have systems in place so that you have the knowledge and act on it. Misreading the manual could prove very costly.

 

 

[jetjr]

Just read it, it could read a few ways, reading further in the manual says more clearly they recommend the following...... As said here

 

The notes in the introduction (which your refering to) also say the requirements are determined by the person doing the work

 

In either case owner, maintainer can determine who is suitable

 

Re directives and similar, surely there could be a way to streamline this, maybe wont cover everything but subscribing to all say Jabiru related alerts (being all AD,SB, notices etcetc) would see many getting to owners. I do agree the current system is flawed. Links from here did work well for me but not up to rec flying to run it.

 

Id also suggest some guidelines for this and other responsibilities of aircraft ownership for the new owner.

 

 

[DonRamsay]

I'm afraid you may be reading this the way you want it to be. I've now talked with Darren Barnfield, the Tech Manager, and he assures me that the statement in section 2.2 is the overriding instruction.

 

If you are still in doubt I would urge you to ring Jabiru for a clarification.

 

Jabiru's intent is pretty clear. They seem to think that all (most of?) the problems with their engines stem from poor maintenance done by amateurs. They want to bar amateurs and require professionals. Hard to read it any other way.

 

If in doubt, read it restrictively and get clarification from the source - the Jabiru Factory.

 

 

[Oscar]

While without doubt, Jabiru may wish to have only 'appropriate' people work on their engines, I can't see this as having any more practical effect than reminding people that there are requirements under various regulations that must be met. As a secondary consideration, of course, it provides some strength to consideration - or rejection - of warranty claims, and here I doubt that Jabiru are exactly on their own in that regard, though others may be able to advise whether e.g. Rotax, Lycoming or Continental happily accept just anybody working on their engines in regard to accepting warranty claims either.

 

Jabiru do not make the regulations specifying 'appropriate' people nor are they able to decree who is/is not 'appropriate' under the regulations. You can do - as far as I am aware - an engine maintenance course at Jabiru, but doing that does NOT automatically make you an L2 and able, for instance, to legally do maintenance on a 24-reg aircraft. You may be judged entirely competent at the end of that course but it in no way (as far as I am aware) gives you any rights unless they are recognised by the regulatory authority. Conversely, as far as I know, you can be an L2 (with accepted expertise in engine maintenance, i.e. not restricted by the terms of your L2 accreditation to NOT working on engine maintenance) and legally do maintenance on a 24-reg Jabiru engine without necessarily having done the Jabiru course. I believe that it is entirely RAA's decision as to who is accredited, and for what activities, as an L2.

 

It may well end up that RAA determines that no L2 who has not done a Jabiru engine maintenance course will be 'approved' to work on Jabiru engines - that is a possibility. However, I don't believe that Jabiru's statement constitutes 'the law' here.