Airworthiness Notices and Directives - how do you stay informed?

[DonRamsay]

Oscar I agree with most of what you write. However, I believe Jabiru are the authority when it comes to how their engines are maintained and who can do it and not just for warranty issues. Mostly this will affect 19 registered aircraft and 24 not used for flight training.

 

What I am concerned about is that people may still believe that ignorance of the rules is an excuse.

 

Another undesirable possibility is maintenance done and not recorded in the log book.

 

And if the AD situation is not great then there are all the regs that RAA do not have an exemption for. Classic of these is the requirement to have your pitot/IAS/ALT/VSI/transponder checked/calibrated ever two years. Few RAA pilots I talk to have any notion that this is a requirement that applies to them.

 

 

[Oscar]

Yep, it certainly needs clarification; for LSA aircraft, it's the manufacturer's call, I suspect (e.g. J160D's, 230D's etc.) and for 19-reg aircraft that have their operational area allowed for a certificated engine, quite possibly the same (or likely to soon be so!). But I suspect that Jabiru can't just say: 'let this be so' and it becomes universally applicable to all Jab engines in all circumstances.

 

While I thoroughly understand the frustration many people have with Jabiru's seemingly very one-sided view of engine problems, I do have some sympathy for their position: Jab. engines are absolutely not something to tinker with unless you know what you are doing - and in quite a bit of the work, have the 'special tools' to hand. ( Not everybody has exactly the same opinion of Jabiru's responsiveness, or lack of it, to problems). That said, I for one will be mightily annoyed if I can't do routine minor maintenance: valve checking, plug checking, leak-down testing, head and through-bolt torque checking etc.

 

Perhaps there is a 'half-way house' solution: Jabiru writes a specific 'course syllabus' that RAA then includes in their L1 training. If there is NOT some accommodation of reasonable, trained owner-maintenance available, then Jabiru would, I suggest, be driving people towards the RPL path (owner-maintenance for at least minor, routine servicing is, to me at least, a major plus for RAA membership vs. going the RPL route) - and surely RAA would not want that to be imposed de-facto on a significant slice of their membership!

 

 

[jetjr]

Have had discussions with Jabiru regarding this and everyone is partially correct however the blame lies, in my opinion,with RAA. It is definitely NOT Jabiru's intention to restrict who can maintain however had to rewrite manuals to comply with new ASTM (for here and US LSA models) ........AND THE NEW RAA OPS MANUAL which basically says what is written, that is, ALL but limited maintenance must be done by L2/LAME

 

The problem of no delineation or definition of what is "limited "maintenance AND also how one becomes L1 to even do inspection type works. Talk of L1 training courses too, Im not aware what. when they have been held?

 

Even this doesnt solve the issue as statement requires L2 not L1 to do maint works.

 

The issue of non LSA aircraft (19 regs) was apparently raised with Darren, unsure of response.

 

Not sure why non ASTM compliant aircraft must conform to ASTM maint requirements. Perhaps an exemption from these requirements on non ASTM aircraft or classify every task in the manual under "limited maintenance"

 

RPL doesnt enable much more maint than new L1 (we think) so that doesnt help either and you need to do MPC. To go further you need to have built the aircraft and engine.

 

So, Don this appears to be a problem based with your reliable source and somehow laying blame at manufacturers feet for writing what they were told.

 

If RAA is pushed (or choosing) down this track and all aircraft have to be L2 serviced then many aircraft wont be going anywhere. Lots of 19 will need to be reverted back to standard trim. Which L2 is going to sign off alterations, no matter how sensible? Let alone there arent nearly enough L2 around. Plenty of LAME wont touch RAA aircraft, a few L2 who shouldnt too.

 

Perhaps you can let us know what is RAA intention in regards to this issue?

 

 

[ave8rr]

So, Don this appears to be a problem based with your reliable source and somehow laying blame at manufacturers feet for writing what they were told.

If RAA is pushed (or choosing) down this track and all aircraft have to be L2 serviced then many aircraft wont be going anywhere. Lots of 19 will need to be reverted back to standard trim. Which L2 is going to sign off alterations, no matter how sensible? Let alone there arent nearly enough L2 around. Plenty of LAME wont touch RAA aircraft, a few L2 who shouldnt too.

 

Perhaps you can let us know what is RAA intention in regards to this issue?

Guess it won't be long before ONLY the original builder of a 19 Reg aircraft will be able to do the maintenance on that aircraft. Once the aircraft is sold then maintenance will have to be done by a L2 / LAME. This is the case with SAAA. I build it then sell then the new owner must have the annual done by a LAME unless that new owner has built a "similar" aircraft. I would say that a lot of this is being forced on RAAus by CASA.

 

 

[jetjr]

I would say that a lot of this is being forced on RAAus by CASA.

Probably but being pushed without a valid case for the increased cost/problems

Being unable to sell on amateur built aircraft is a big restriction in SAAA Id say, big value loss to builder too.

 

Id estimate 40-50% of RAA are 19 or similar reg effected by this. Many been maintained for many hundreds of hours by non building owners.

 

If the rules on maint are headed the same way, RPL and SAAA is far more attractive with increased weight limits etc and lower costs of licence/reg/membership

 

 

[dazza 38]

I don't know why all of a sudden Pilot certificate holder/L1 operators cant be trusted. It isn't as if aircraft are falling out of the sky due to poor owner maintenance. Sure there may be the old occasion but generally I think that the majority L1 guys are doing a good job. People who are not confident in working on their own aircraft go and get help/advice or a L2 to do the work. As a guy who worked on F111's for nearly 9 years and Tornado's for 2 years and doing bits and pieces on Ultra lights for many years as a L1, it will not be acceptable if all of a sudden I am told that I cannot perform work as a L1. That wont wash with me.

 

 

[jetjr]

How about advanced L1 or restricted L2 only able to work on owned aircraft and further training/assessment for competence on type.

 

Theres a potential big gap between current L1 and commercial working L2 especially with newer push for currency to remain one

 

 

[robinsm]

Don't give a rats..., I built the thing, I maintain its engine be it Rotax, jabiru or VW. If these engines are that delicate and particular then who would want to buy one...Just sayin..

 

 

[jetjr]

Point is robinsm this is proposed for ALL aircraft, all engines, if you built it or not, no differentiation as it reads currently.

 

As was clarified this has nothing to do with Jabiru

 

 

[Oscar]

Horses for courses, Dazza. We all know people who have 'lover's hands' but persist on working on things they should not. Heck, we have a regular contributor in here who is an L2 but apparently doesn't know the use of Belleville washers from Blue-tack for propellor retention. I can't see the objection to having a basic competence course being a requirement; it's blanket rejection of disparate competence that is surely the issue?

 

 

[jetjr]

robinsm YOU did not build the engine so you can not maintane it so that argument does not hold waterSame as GA and SAAA You can't work on a engine more than sceduled maintenance

And thats the problem, many experienced owners and some L2 have been doing next level maint succesfully for years and its the main reason for sticking with RAA. We have other restrictions like weight, airspace, stall speed as a result of these priviledges so why need same as GA rules

 

Loose this loose lots of members

 

Current way its proposed says maybe L1 cant even do scheduled work.

 

 

[dazza 38]

Horses for courses, Dazza. We all know people who have 'lover's hands' but persist on working on things they should not. Heck, we have a regular contributor in here who is an L2 but apparently doesn't know the use of Belleville washers from Blue-tack for propellor retention. I can't see the objection to having a basic competence course being a requirement; it's blanket rejection of disparate competence that is surely the issue?

Hi Oscar, I hear what you're saying, but i feel that most humans have self preservation and nearly all the pilots I know including me, will ask for advice for things that we don't know. My specialty is airframes and jet engines, not piston engines. For that type of work, apart from the basic stuff ( oil, spark plug changes ect) I will seek a L1 /l2 with the qualifications and who know that kind of stuff.

 

 

[robinsm]

No I didn't make the engine, but then I didn't extrude the aluminium, knit the cloth or make the instruments,...your argument is...???

 

 

[Oscar]

Hi Oscar, I hear what you're saying, but i feel that most humans have self preservation and nearly all the pilots I know including me, will ask for advice for things that we don't know. My specialty is airframes and jet engines, not piston engines. For that type of work, apart from the basic stuff ( oil, spark plug changes ect) I will seek a L1 /l2 with the qualifications and who know that kind of stuff.

Dazza - you have the invaluable knowledge of what can go wrong, so you temper your work accordingly. Many do not. To quote my favorite author, Terry Pratchett: '(XX) had an acute sense of his own inadequacy - an affliction that besets altogether too few people..'

 

 

[jetjr]

A key part to this debate is the wide scope between changing oil and full overhaul, its not one or the other

 

Currently L1 can do it all relying on their own understanding of limits. Some competence based training would allow self maintainers to extend to everything up to a certain level.

 

With an simple engine like Jabiru needing quite in depth regular work. Extra work like additional leakdowns or valve adjustment, pushing for L2 only will stop this happening and will in fact reduce the amount of preventative works being done.

 

 

[kgwilson]

Section 2.2 of the Jabiru Engine Maintenance Manual dated 12 May 2014 is word for word identical to Jabiru Engine Maintenance Manual dated 26 July 2012. This is also the case for the section entitled "Maintainer requirements" although it is now Section 6 not section 5 as a new CASA Approved section 4 "Airworthiness Limitations" has been added. Nothing has changed other than some people having actually read the new version when they had not read the earlier one.

 

 

[DonRamsay]

KGW, as you know, I have already pleaded guilty to not having read the manual in detail but when provoked did read 2.2 To my understanding of the English language it is quite clear. If that is not new then there have been, in all likelihood, a lot of people doing the wrong thing perhaps without knowing that.

 

Any aspersions or innuendos as to Jabiru's reason for section 2.2 are my own supposition and probably not helpful.

 

As we haven't seen the soon to be released RAA Tech Manual, we can't know what part RAA had in the composition of 2.2 If as you say this is along standing instruction by Jabiru then it is not something dreamed up by the current Tech Manager or related to the new Tech Manual.

 

 

[Admin]

I have always got a LAME to do any work on my aircraft...I wouldn't touch anything myself...my argument is that I would always feel better blaming someone else as I fell out of the sky.

 

The AD I mentioned earlier on my CTsw was for the parachute handle...not something that you would want to not work if you ever needed it

 

 

[DonRamsay]

When our small syndicate of three acquired our Tecnam, there was an immediate meeting of minds as to who would get to maintain our aircraft - we all enthusiastically agreed that we would only allow a respected L2 to work on our aircraft. We also agreed that one of the three of us would be the primary overseer of maintenance to ensure nothing was missed. So far, that's working very well. However, we each have a responsibility to ensure the aircraft is airworthy before the wheels leave the ground when we are PIC.

 

 

[kgwilson]

KGW, as you know, I have already pleaded guilty to not having read the manual in detail but when provoked did read 2.2 To my understanding of the English language it is quite clear. If that is not new then there have been, in all likelihood, a lot of people doing the wrong thing perhaps without knowing that.Any aspersions or innuendos as to Jabiru's reason for section 2.2 are my own supposition and probably not helpful.

 

As we haven't seen the soon to be released RAA Tech Manual, we can't know what part RAA had in the composition of 2.2 If as you say this is along standing instruction by Jabiru then it is not something dreamed up by the current Tech Manager or related to the new Tech Manual.

Don, I was not trying to show you up, I was just pointing out that the Jabiru maintenance manual has not changed, in fact the relevant sections have been the same for some years but I only have 2012 & 2014 copies. It is just that with CASA shaking the cage the rank & file are becoming aware of these things.

Pity that half the downloads from the Technical page of RA-Aus website don't work.

 

 

[DonRamsay]

. . . I was just pointing out that the Jabiru maintenance manual has not changed, in fact the relevant sections have been the same for some years but I only have 2012 & 2014 copies. It is just that with CASA shaking the cage the rank & file are becoming aware of these things.

No worries KGW and thanks for the explanation. Your post added important and helpful information regarding what is in the Jab manual and must have put beyond doubt that this is not a new requirement imposed by RA-Aus but a long standing Jabiru requirement that most of us have been happily unaware of but was our responsibility to know (if we fly Jabiru).

 

Pity that half the downloads from the Technical page of RA-Aus website don't work.

I had noticed that when I went looking for the May 2014 Jab Maint Manual and did nothing about it. I just checked and found two more that didn't work and have now reported them all to RA-Aus to get them fixed or removed. Wish I'd done that when I first discovered them.

 

 

[Admin]

Don, I made the RAAus, and some board members, fully aware of the issues with AD's and AN's on the web site back in Feb 2012 (nearly 2.5 years ago) and nothing was done. Two months later I tried again however, still nothing was done. By Sept 2012 I had become so frustrated that such potentially life saving information was not accurate, was broken and contained omissions that I went to CASA about it. This is the reply I received from CASA:

 

It should be noted that it is not the responsibility of RA-Aus to ensure that AD’s are complied with. It should also be noted that, in accordance with CASR 1998 200.002, 200.013 and 200.014, RA-Aus aircraft other than LSA aircraft, are exempt from compliance with ADs. However, RA-Aus aircraft are not exempt from ANs that have been issued by RA-Aus and as such, RA-Aus is required to have a process of providing access to ANs that have been issued. This they do via their Safety page on the RA-Aus website. Of course, any AD that is applicable to an RA-Aus aircraft should be carried out as these are based on manufacturers requirements anyway.

 

 

 

It is not a lawful requirement for the RA-Aus to publish the ADs on their website but they do this as a service to their members. It is the responsibility of the owner of an aircraft to ensure that they are kept informed of any current Airworthiness bulletins/notices/service bulletins that are issued by the manufacturer by accessing the manufacturer’s website on a regular basis as RA-Aus aircraft are not exempt from manufacturers service bulletins/directives or requirements.

 

 

 

I hope that this information clarifies your concerns that you raised as to the listing of ADs and ANs on the RA-Aus website. If you have any further questions relating to this matter, please do not hesitate to contact the SASAO team to discuss and we will be more than happy to provide guidance.

 

 

[DonRamsay]

Thanks Ian. I understand both your keen interest and frustration on this. Fact is there has never been enough attention given to the RA-Aus website. It was at the February 2012 Board Meeting that the Board approved the re-working of the website. As had happened in the past it took forever and while improved was still way below par. Content accuracy and currentness continues to be an issue.

 

From the little I hear of the new CEO he is very keen to do a lot of things much better than they have been done in the past and is for once getting majority support from the Board to make the changes that are long overdue.

 

The note from CASA is both illuminating and authoritative.

 

That a non-LSA (RA-Aus) aircraft may be exempt from an AD is not going to affect the laws of physics when it comes to aircraft falling from the sky. Anyone who felt they were exempt would have to be pretty "brave" not to act on it.

 

Don

 

 

[Admin]

Don't get me started on the the whole website thing however I will say that a couple of board members said to me afterwards that they should have accepted my $1 offer to do their site, wow what a website they would have had and being that they paid $1 meant a commercial agreement was entered into thus giving them FULL control...in fact I even offered them a 100% discount if paid within 7 days. In terms of having online forms, I could set them up here on Rec Fly within just a few hours giving everyone an online form experience however not being linked to their database they would be automatically emailed to them in an excel spreadsheet...in fact the online form software has already been installed here on Rec Fly but not used.

 

Imagine giving aircraft manufacturers Australian agents/representatives the ability to automatically add an AD or AN into the website with an alert going to the Tech Mgr...saves the Tech Mgr time and puts the information release closer to the source i.e. the manufacturer.

 

 

[Guest john]

Don't get me started on the the whole website thing however I will say that a couple of board members said to me afterwards that they should have accepted my $1 offer to do their site, wow what a website they would have had and being that they paid $1 meant a commercial agreement was entered into thus giving them FULL control...in fact I even offered them a 100% discount if paid within 7 days. In terms of having online forms, I could set them up here on Rec Fly within just a few hours giving everyone an online form experience however not being linked to their database they would be automatically emailed to them in an excel spreadsheet...in fact the online form software has already been installed here on Rec Fly but not used.Imagine giving aircraft manufacturers Australian agents/representatives the ability to automatically add an AD or AN into the website with an alert going to the Tech Mgr...saves the Tech Mgr time and puts the information release closer to the source i.e. the manufacturer.

Hi Ian,

It goes to show that the Hieharacy in most organisations such as RAA don't like being told or offered a helping hand. Once they get elected & get the "Administrative Injection" they think that they are smarter than the rank & file, after which they talk down to you & they expect you to talk up to them. They have already forgotten that "The crumbs maketh the bread".

 

Theres an old saying that this generation have forgotten: "You don't knock a gift horse in the mouth".