CASA 292/14 - Conditions and direction about Jabiru engines

[turboplanner]

And the Performance Standard that Jabiru has breached is?

This isn't a comprehensive training site, so if you prefer: "standard of performance" or "performance based" or even just "performance"

All are part of today's terms.

 

 

[turboplanner]

There is no nationally decreed nor internationally agreed 'reliability' standard

In that part of your post you are correct, and I would suggest there is not likely to be one any time soon.

The reason is that if CASA specified one, who is to say they are correct? If they decide on a standard that is too lenient and people die, it can be very costly to the government.

 

The way CASA is reacting is no different to any other government department.

 

Based on this, the rest of your statement falls away.

 

 

[facthunter]

It would however be reasonable to assume that motors less reliable than Jabiru, could come in for attention as well eventually, if one applied logic and fairness to any of this. Nev

 

 

[jetjr]

And the draft ATSB report says Rotax and Jab fail "about the same"rate

 

Should be of serious concern that rotax failures are uniformly increasing in frequency.

 

 

[turboplanner]

As I recall the ATSB had very low numbers, but the statistics can be collected from quite a number of different sources.

 

 

[gandalph]

This isn't a comprehensive training site, so if you prefer: "standard of performance" or "performance based" or even just "performance"All are part of today's terms.

"Performance standards" were your words TP not mine. (post# 793)

However I'm glad to see that we can at last agree on something: There is no performance standard - published, notional or otherwise, that Jabiru engines have breached. Perhaps the discussion can move on from there.

 

 

[jetjr]

As I recall the ATSB had very low numbers, but the statistics can be collected from quite a number of different sources.

And your point being?

 

US data shows Jabiru in good light too

 

 

[turboplanner]

It would however be reasonable to assume that motors less reliable than Jabiru, could come in for attention as well eventually, if one applied logic and fairness to any of this. Nev

Yes, you would expect that.

Wire rope barriers have been a huge success on our highways, and I've done a lot of highway work this year and noticed that whereever there's a new cross beside trees or on a causeway, there's usually a new section of cable, so in that case the Road Authority trigger is one fatal accident.

 

 

[turboplanner]

"Performance standards" were your words TP not mine. (post# 793)However I'm glad to see that we can at last agree on something: There is no performance standard - published, notional or otherwise, that Jabiru engines have breached. Perhaps the discussion can move on from there.

Yes, you've got it, the industry has been moving on from management by prescribed specifications for some years. Where previously if the manufacturer didn't breach a standard set by the government he was safe and the government took the hit.

By removing the specification standard the manufacture was on his own.

 

By setting a performance based standard as is done in the auto industry, manufacturers can choose any specification it likes, as long as its performance meets the standard.

 

Where higher risks are involved, the government has tended to leave all the risk with the participants but will move in based on its own triggers. We are in the last group.

 

 

[gandalph]

Turbs, Without wishing to relight the fires of dissent. You talk about government removing a standard - putting aside for the moment the fact, now agreed, that there is not, and was not and standard set by government- and go on to say that a manufacturer can choose any specification it likes, as long as it meets the standard. What standard? There is a circularity to your proposition and it simply doesn't gel. I'm sure that Jabiru won't agree that it doesn't meet the specifications it set and therefore doesn't meet it's standards.

 

So we seem to be left with the proposition that an agency responsible to the federal government and controlled whether directly or indirectly by that government appears to have formed the opinion that a particular make of engine (at present that's Jabiru) doesn't meet an industry standard that doesn't exist, or that the agency has formulated a standard but has declined or neglected to publish or publicise that standard and then acted unilaterally against a manufacturer because of its belief that this "standard" has been breached.

 

If I have understood the thrust of many of the posters here, that is a serious point of contention.

 

And for the benefit of FT. None of what I've said above can or should be construed as me saying that CASA has acted illegally.

 

 

[Guest john]

Considering past defects with GA Manufacturers such as Cessna, Piper, Mooney , Beechcraft etc. if the defect is of a serious nature then the Countries Regulators issue an AIRWORTHINESS DIRECTIVE (AD)which is mandatory , which procedure is what CASA could have done with the Jabiru engine issue if they had serious concerns regarding the technical defects with the Jabiru engine, however they decided for whatever reason to take a different approach to this matter, as it appears that they did not have sufficient factual details to issue an AIRWORTHINESS DIRECTIVE & it appears now the ball has now backfired onto their side of the court.

 

 

[gandalph]

John, I'd suggest that one of the the reasons that CASA didn't take the AD route is that there has been little of no forensic investigation into the root cause(s) of engine failures in RAA aircraft either Jabiru or other makes. I'll insert the caveat here that CAMit has been conducting for some considerable time, exhaustive investigations into the root causes of jabiru failures and developing modification to address those causes they have identified. I do not include them in my criticism above .

 

I may well be doing RAA's techies a grave disservice by suggesting that their analysis of engine failure goes no deeper than the discovery that an engine had dropped a valve or broken a through bolt or shed a prop etc. Before people rise up from their beds shouting (again) "that's not the RAA's job" let me say I agree, in part. But if the aircraft was GA reg, the regulator would want to know what caused the valve to drop, what caused the through bolt to break etc. That way it could fullfil its role as safety regulator by issuing an AD to either inspect i.e "look for these warning signs" and/or fix the following identified faults. To support my assertion, I cannot recall any GA incident investigated and reported in the crash comic where the conclusion was that, to paraphrase: "the engine stopped and the plane crashed" It is my opinion that the RAA, as delegated sub-regulator - if you like- should be bringing pressure to bear on the engine manufacturers to conduct those forensic in depth investigations or asking big brother (CASA) to apply that pressure. Or else we should be seeking funding from government to allow RAA to develop those skills and conduct those investigations.

 

CASA couldn't/didn't issue and AD because they didn't/don't know what the problem(s) are. So they felt, for whatever reasons (and we don't want to re-start that bushfire on here. That's now history and unchangeable) that they had to take some form of action.

 

In the current case CASA seems to have had a bob each way shouting "We don't believe Jabirus have been doing as well as we think they should compared to...... um, er, AND we don't know what the problem is but we wish someone would tell us what it is, AND we think it is so serious thatis causes such immediate danger to someone (not entirely sure who, but we'll work on that one) that we're going to stop people flying with these engines unless they sign a bit of paper saying they're ok with it. AND you , or someone else , had better fix whatever it that's causing whatever it is that's worrying us AND then tell us so we can see if we agree and save face".

 

(Note to TP: I don't really think that's exactly what they said. I was paraphrasing and taking just a little bit of a literary license there)

 

Note to FT: None of what I've said above can or should be construed as me saying that CASA has acted illegally.

 

 

[Oscar]

The idea that National/International Airworthiness Authorities have moved from the use of prescribed standards of performance for the demonstration by manufacturers of Compliance, is quite transparently incorrect. Nobody with a shred of understanding of the requirements for Certification / Certifying would make such a suggestion.

 

End of.

 

 

[Camel]

AD (airworthy directive) are issued for certified aircraft not LSA.

 

Service letter or Bullentines for LSA,

 

From Jabiru website.

 

LSA Owner/Operator Responsibilities

 

The following responsibilities for the owner/operator of a LSA listed are prescribed in the ASTM standard F2295:

 

• Each owner/operator of a LSA shall read and comply with the maintenance and continued airworthiness information and instructions provided by the manufacturer.
   
   
  
• Each owner/operator of a LSA shall be responsible for providing the manufacturer with current contact information where the manufacturer may send the owner/operator supplemental notification bulletins.
   
   
  
• The owner/operator of a LSA shall be responsible for notifying the manufacturer of any safety of flight issue or significant service difficulty upon discovery.
   
   
  
• The owner/operator of a LSA shall be responsible for complying with all manufacturer issued notices of corrective action and for complying with all applicable aviation authority regulations in regard to maintaining the airworthiness of the LSA.
   
   
  
• An owner of a LSA shall ensure that any needed corrective action be completed as specified in a notice, or by the next scheduled annual inspection.
   
   
  
• Should an owner/operator not comply with any mandatory service requirement, the LSA shall be considered not in compliance with applicable ASTM standards and may be subject to regulatory action by the presiding aviation authority.
   
   
  

 

 

 

 

[gandalph]

True Camel, and I apologise if my use of the term Airworthiness Directive (AD) has confused anybody but I would point out that not all RAA aircraft are LSA's

 

 

[turboplanner]

It is not going to be possible to contract thousands of documents over three decades on a moving scale and finish up with a post which explains it all.

 

I was talking about very basic principles, and left Jabiru out of it. You've weaved it back in so here's a second attempt:

 

You talk about government removing a standard

Here's an example which I was involved in:

 

Prescribed Specification (pre 1980s): "Spectators must be 4 metres clear of the Safety fence" (Government is liable for its decision that 4 metres is safe.

 

Specification Removed: " Spectators must be protected" [or it may say nothing at all] (Participants make the specification decision and take liability.)

 

- putting aside for the moment the fact, now agreed, that there is not, and was not and standard set by government

Since we were not talking about Jabiru, we won't confuse the issue, but we agree it sits in the newer category.

 

and go on to say that a manufacturer can choose any specification it likes, as long as it meets the standard. What standard?

I'm now talking about the performance requirement, which is that spectators must be protected. (Standard would be the ADR if it was a car)

 

So we seem to be left with the proposition that an agency responsible to the federal government and controlled whether directly or indirectly by that government appears to have formed the opinion that a particular make of engine (at present that's Jabiru) doesn't meet an industry standard that doesn't exist, or that the agency has formulated a standard but has declined or neglected to publish or publicise that standard and then acted unilaterally against a manufacturer because of its belief that this "standard" has been breached.

With what I've just explained the fixation on the word standard can be removed, so that scenario does not apply.

 

Most Responsible Authorities these days are just assessing safety day by day based on observations and evidence, and act on their own triggers. In fact there was mention on this in the Dick Smith thread #1 pdf attachment:

 

"Some airports such as Coffs Harbour, in northern NSW and with about 350,000 passenger movements, are under designated controlled airspace. Coffs has a control tower. Ballina, with about 430,000 passengers, does not.

 

A Civil Aviation Safety Authority spokesman says the agency is required to assess changes to airspace based on risk, “not hard triggers such as passenger numbers”."

 

That's probably not mentioned anywhere, just as in this case there were no prescribed specifications which many people seem to have been looking for.

 

I'm not saying operating out there without the tightrope of a prescribed standard is fair, and I suspect I had a lot to do with Road Safety Acts in 1999 at least spelling out to people that they must comply with vehicle standards and codes of practice which they had established and thought were voluntary, which at least in the transport industry has removed a lot of uncertainty. But bear in mind the purpose of these changes were to remove the liability from the government to us, and that's also the reason DIRD over the decades has been removing engineers.

 

The Shire of Wentworth case I posted a couple of days ago was a good example of where a Council received no warning at all that a particular curve in a road didn't have consistent warning signs.

 

Which is why I'm suggesting that chasing after numbers or comparing numbers is a lost cause.

 

If CASA identifies a risk for whatever reason, you can expect them to act.

 

Which is why I'm suggesting finding out what all last year was about and what the situation is this year and what can be done to minimise cost and disruption.

 

 

[gandalph]

Yes Oscar but the discussion was in relation performance standards for engine performance rather than performance standards for airframe performance. But, as you say, the notion that a manufacturer could set a performance standard for their airframe without reference to the performance standards set by the relevant regulatory authorities is a nonsense.

 

 

[fly_tornado]

I can move on, can you accept that CASA have done the right or wrong thing Gandy and move on?

 

Or are you going to "maintain the rage", even though it achieves nothing?

 

 

[gandalph]

You are a funny bloke FT. You keep pushing for something when there's nothing there. But least you've downgraded your cross examination theme from "have acting illegally" to " have they done the right or wrong thing." I continue to wonder why what I think is so important to you. I'd like to say I'm flattered, but I'm not. Your peculiar questions and posts make it very difficult for me (can't speak for others here)to take you seriously.

 

"Maintain the rage"? Against who? Against what? ROFLMAO! What are you on about? Or perhaps I should ask: What are you on?

 

BTW that's more funny peculiar than funny Ha Ha.

 

 

[fly_tornado]

I can feel your rage boiling through my TV!

 

 

[gandalph]

I can feel your rage boiling through my TV!

FT you don't have what it takes to get me hot.

I'm pretty sure it's not rage you're feeling mate but I'm open minded, so what ever gives you your solitary pleasure is ok so long as you don't go into details about it.

 

 

[fly_tornado]

Gandy, do you feel like a gopher trapped on an exercise wheel dealing with simple minded folk like myself?

 

 

[turboplanner]

The idea that National/International Airworthiness Authorities have moved from the use of prescribed standards of performance for the demonstration by manufacturers of Compliance, is quite transparently incorrect. Nobody with a shred of understanding of the requirements for Certification / Certifying would make such a suggestion.End of.

Oscar, I simplified the discussion so that people could understand the situation relating to the subject matter of this thread, which is specifically related to 292/14

I'm not about to make a 500 page post to include every nuance, every facet of our system.

 

 

[Oscar]

Yes Oscar but the discussion was in relation performance standards for engine performance rather than performance standards for airframe performance. But, as you say, the notion that a manufacturer could set a performance standard for their airframe without reference to the performance standards set by the relevant regulatory authorities is a nonsense.

Um, there are performance standards for engines. Jabiru hold JAR 22H certification for the 2200, and certify the 3300 against ASTM.

 

 

[turboplanner]

For goodness sake Oscar, move down from the certification level to the manufacturing and operating level, unless of course you'd like to turn the flame back up the tree to that level and turn the spotlight on them.