Random Paperwork Inspections

[Keith Page]

Hello kasper,

 

As yet the draft V4 Tech Manual has not had a read. Waiting for my mag to turn up.

 

To me this sounds like the constitution - shown to the members in a shabby form.

 

Why not get it about correct before it is presented? This is same as the constitution.

 

I am wondering who has the idea that RAAus has got to have more regulation than GA?

 

The concept of AUF has drifted off in the clouds.

 

RAAus is a members organisation I think the members should be listened too.

 

OR Does RAAus want to loose all its members.?

 

Regards

 

KP

 

 

[kasper]

Kasper,Some good points well made. I'll be getting a thorough briefing on this matter on Saturday and nothing that has been published to date will be in the final, approved V4 unless both a Board majority and CASA approve the document. But that day is drawing very close.

Whether V4 is perfect or just a quantum leap over the current awful document is not a bad position to be in. And there will be a V4.1

 

There is just too much improvement on offer to delay much longer.

 

I appreciate heads-up on all these things and will have them on my notepad at the Board Meeting. Wish me luck!

 

Don

 

p.s. I know, I know . . . it's not supposed to be about luck . . .

And its also not supposed to be about 'its better than we have even though its not what we would/should have'

The fact that there will be a 4.1 should in my opinion not in any way allow through in 4.0 new regulation, cost and bureaucracy that is not supported by a risk based assessment.

 

Loath to tie this to the argument that the Constitution as presented is not the best but its better and we need to move forward ... but the comparison might be made.

 

have fun on the briefing ... and FYI your notes from members on areas to explain MIGHT have been a touch more timely and complete IF the draft had been released to members for comment ... just saying

 

 

[rhtrudder]

Unsure about the l1 maintainer online training wouldn't this be open to cheating ,is it in the form of a test, what happens if you fail miserably , do you have to hand your badge back in,or have I got this all wrong wouldn't be the first time

 

 

[kasper]

Unsure about the l1 maintainer online training wouldn't this be open to cheating ,is it in the form of a test, what happens if you fail miserably , do you have to hand your badge back in,or have I got this all wrong wouldn't be the first time

From the Mag you will not be allowed to do any maintenance without the L1 pass after the 6mth transition period ...

Its going to be interesting to see what happens with L2s ... are we allowed to do our own maintenance without having to pass the L1.

 

And from my perspective if the L1 assessment is anything like the trial version RAAus put out all the questions on 'what's this really for?' remain.

 

If it covers the legalities of maintenance but not the practicalities of maintenance is this form over function?

 

Is it form ticking showing you know WHERE and WHAT the requirements on doing and recording Maintenance is BUT is it forgetting to teach you HOW to DO the maintenance?

 

 

[rhtrudder]

I know of the odd pilot that are puzzled by how a nut screws on a bolt , but are still safe enough in the air and been flying for years, will this make any difference for them as I don't think it will teach them how to do any maintenance if its only ticking boxes

 

 

[Geoff13]

Say what you like about CASA, at least they introduce changes much more slowly and with much more consultation (or at least publicity) than RAA.

Ask some of the Jabiru owners how they feel about that! Just sayin'

 

 

[Oscar]

Kasper - as a builder yourself, you will KNOW that you cannot expect to train people on-line about HOW to do maintenance.

 

How do you teach people on-line to recognise that they've exceeded the elastic limits of the nut thread they've just over-tightened and partially stripped? You will know as well as anybody, that there are people we classify as having 'lover's hands' ( i.e., they f$ck everything they touch..) How many L1 maintainers have a set of number drills for accurate-specification rivet holes? Or a set of expanding reamers for holes for bolts needing to be a close-tolerance fit to the hole?. Not to use a pencil to mark aluminium parts? Where to use lithium grease instead of graphite grease? How many have calibrated torque wrenches? Cable tensiometers? Safety wire pliers and the knowledge of how to use them correctly?

 

I've seen - on a thread on this site - someone cheerfully announcing that they had found that silicon bronze filler rod was a good, cheap replacement for the pins on 5052 piano hinge on primary control surfaces - FFS.

 

You would know every bolt, nut and rivet on your self-built single-seater. Would you just jump into the rh seat of an aircraft built and maintained by somebody else whose proficiency you did not know, on the basis they had an L1 ?

 

 

[DonRamsay]

I know of the odd pilot that are puzzled by how a nut screws on a bolt , but are still safe enough in the air and been flying for years, will this make any difference for them as I don't think it will teach them how to do any maintenance if its only ticking boxes

You don't need the L1 to be a pilot. L1 was a give away with the pilot cert whether you could tell the difference between a right handed and left handed screwdriver or not.

Without an L1 you will be restricted in what maintenance you can do. With an L1 it is to me alarming what you can do . . . but that is the spirit of RAAus and I'm never going to campaign against it but I will continue to be selective about what aircraft I will accept a ride in.

 

 

[aro]

Our endorsements do not represent more regulation than GA. Just called different things in GA like "type", etc. Show me a PPL who has not had to jump through a hoop for Radio, carrying passengers, Navs, NW/TW, etc. We just give them endorsement names.

None of the items I listed require endorsements in GA, and there are only a few aircraft that require type ratings - it would be pretty rare for your day VFR PPL to encounter one. Some aircraft owners might require training if you rent, but that is different to regulation.

 

I was denied my certificate renewal a few years back because I hadn't provided details of my AFR

 

Can't see a problem there.

At the time AFR details didn't need to be notified to CASA, just entered in the logbook (this has now changed with Part 61).

 

then I needed to sit the additional human factors exam.

 

HF is just as relevant to a RA as a GA pilot. Still the biggest cause of aviation fatalities by far. Nobody is ever going to apologise for requiring a knowledge of HF.

Not my point - my point is that these are all "regulations" that apply to RAA over and above what applies to GA pilots. Sure some of them might be a good idea, (although the HF exam had questions about SCUBA diving that I think were dangerously out of date) it doesn't change the fact that they do not apply to GA.

 

You said:

 

We do have a principle that we hold dear in RAAus and that is that we should not have regulation for which GA does not have regulation

did you mean to add "unless the RAA hierarchy decide it's a good idea"?

 

 

[DonRamsay]

None of the items I listed require endorsements in GA, and there are only a few aircraft that require type ratings - it would be pretty rare for your day VFR PPL to encounter one. Some aircraft owners might require training if you rent, but that is different to regulation.

I think we're arguing in circles here. You call it RAAus regulation and I call it part of normal PPL training and qualification. Personally, I'd like to see most endos deleted other than Navs and Low Level/Rural. All the rest should be required for a Pilot Cert. with the possible exception of Radio for people who operate aircraft for which radio is impractical (is there such a thing?).

 

At the time AFR details didn't need to be notified to CASA, just entered in the logbook (this has now changed with Part 61).

How would RAAus know you have done an AFR (which covers you for BFR requirements) unless you told RAAus?

 

Not my point - my point is that these are all "regulations" that apply to RAA over and above what applies to GA pilots. Sure some of them might be a good idea, (although the HF exam had questions about SCUBA diving that I think were dangerously out of date) it doesn't change the fact that they do not apply to GA.

Have you advised a CFI, the Ops Manager or CEO of what's wrong with the answers relating to scuba diving? I swallowed the HF exam and Suba theory without any other experience to doubt it. I'd like to know for myself and I'd very much like to make sure we are not spreading urban myths if that is what we are doing.

 

. . . did you mean to add "unless the RAA hierarchy decide it's a good idea"?

Yes, funnily enough I did mean to add that. But I can tell you that no "good idea" gets past the Board without something akin to the Spanish Inquisition.

If I can bore everybody for just a few moments longer, let me give you my theory on regulation - what works and what doesn't.

 

Firstly, according to AOPA, what CASA does now has been proved over a period of 18 years to statistically make no difference to safety outcomes.

 

Secondly, regulations have never stopped pilots running out of fuel but I think the CASA CAAP 234-1 probably has. Point is, good advice will be picked up by pilots because it is clearly good advice. My predictions is that stupid regulations like those proposed on fuel management to replace the CAAP will be ignored by ordinary pilots and will achieve nothing but bring CASA and their CASRs into disrepute.

 

Thirdly, the sheer volume and complexity and legalese makes the CASRs all but unintelligible to the part-time pilot, both GA and RA. At least RA has a better chance with the more compact Ops Manual.

 

So, Safety organisations like CASA improve safety of pilots, their passengers and the public by supporting education and training in how to balance the risks of aviation. Fining somebody $9,000 for not calling "MAYDAY" when their fuel reserve dropped below 45 mins even though they were in sight of an airport will just cause people to give up aviation forever.

 

Compare the value of the safety sessions conducted by CASA's Teraya with yet another 32 pages of regulations? Lay down grand slam.

 

So, what about RAAus and regulation? It is subservient to the huge raft of legislation drafted by CASA - is there any wonder it looks a bit like it? Under the current legislative framework, is there an alternative?

 

If I ruled the world, I think I could get RAAus's (and non-commercial GA's) regulation's down to one sentence:

 

"The Pilot in Command is to take all sensible precautions to ensure their flight is conducted and concluded safely".

 

Penalty: Injury (possibly fatal), destruction of aircraft and other property and possible loss of insurance cover.

 

Then, instead of spending hundreds of millions of dollars and decades devising ways to fine pilots and maintainers, CASA could hire 500 enthusiastic aviations personnel who would spend their time, not in air conditioned offices in Canberra, but out and about at every airfield in Australia helping us to get it right.

 

 

[turboplanner]

If I ruled the world, I think I could get RAAus's (and non-commercial GA's) regulation's down to one sentence:

"The Pilot in Command is to take all sensible precautions to ensure their flight is conducted and concluded safely".

 

Penalty: Injury (possibly fatal), destruction of aircraft and other property and possible loss of insurance cover.

Fortunately you don't rule the world; that statement beggars belief in 2016.

 

 

[kasper]

You don't need the L1 to be a pilot. L1 was a give away with the pilot cert whether you could tell the difference between a right handed and left handed screwdriver or not.Without an L1 you will be restricted in what maintenance you can do. With an L1 it is to me alarming what you can do . . . but that is the spirit of RAAus and I'm never going to campaign against it but I will continue to be selective about what aircraft I will accept a ride in.

Oooooooo Red rag to a bull!!!

As Oscar noted I hold an L2 and did work in GA that is the basis of my L2 AND I am an instructor AND I have built several aircraft AND operated in a fully certified aircraft manufacturing factory so I have a background here (add in accountant, solicitor and certified programme manager) and I am basically a professional PITA on process and form over function.

 

I HATE when people say the L1 was a give away with the pilots certificate ... it never was when I was instructing in the mid 1990's ... you get your pilots certificate I did briefings on airframes, engines, systems and the student had to actually understand how things worked and how to visually inspect ... and they ALL got walk through of a service on the aircraft (all the instructors were also L2's at the school) and by the end the pilots certificate holders knew enough to know what they needed to look at keep an eye on and recognize what they were not comfortable to do...regardless of them owning an aircraft or not.

 

If the issue is that people need to understand the practicals of aircraft maintenance then an online test is in my opinion not the way to go...focus on the instructors and the syllabus for the pilots certificate.

 

Why am I so anti-online learning that is NOT practical? ... the change as outlined in the mag applies equally to all existing pilots - what about me (or any other pilot) who has an aircraft that was home built by themselves ... they are the design authority on that airframe and it would end up in a situation that after the 6mth transition period until you passed your L1 online you CAN design manufacture modify and fit modifications to your aircraft but you are CANNOT do maintenance! eg I can take a prop off and replace it with a different prop (a mod) but could not take the existing prop off and inspect it for wear and refit it because that is maintenace. equally I could design and fit a dry sump system to an engine (a mod) but not do an oil and filter change (maintenance)

 

This is just

 

 

[frank marriott]

Don, a close read of CAO 95.55 might might be informative for you.

 

 

[facthunter]

If a maintainer had his authority cancelled what status should the aircraft he/she has been working on recently have? I think the answer is obvious. It should be inspected again.

 

Some people with a good feel for torquing nuts can get very close to the torque wrench figure. Likewise when torquing with a wrench they should feel the bolt yielding if it's the wrong metal and doesn't have enough strength. People electroplate structural parts with no knowledge whatever of hydrogen embrittlement and it's effects. Nylock nuts on hot parts. Stuff not properly tabbed or lockwired. Plenty to be concerned about. People need to be educated, not fined and made to take it to people who may not do the job right either. Due to the way we operate we must be more personally involved with OUR aircraft. Nev

 

 

[kasper]

Kasper - as a builder yourself, you will KNOW that you cannot expect to train people on-line about HOW to do maintenance. How do you teach people on-line to recognise that they've exceeded the elastic limits of the nut thread they've just over-tightened and partially stripped? You will know as well as anybody, that there are people we classify as having 'lover's hands' ( i.e., they f$ck everything they touch..) How many L1 maintainers have a set of number drills for accurate-specification rivet holes? Or a set of expanding reamers for holes for bolts needing to be a close-tolerance fit to the hole?. Not to use a pencil to mark aluminium parts? Where to use lithium grease instead of graphite grease? How many have calibrated torque wrenches? Cable tensiometers? Safety wire pliers and the knowledge of how to use them correctly?

 

I've seen - on a thread on this site - someone cheerfully announcing that they had found that silicon bronze filler rod was a good, cheap replacement for the pins on 5052 piano hinge on primary control surfaces - FFS.

 

You would know every bolt, nut and rivet on your self-built single-seater. Would you just jump into the rh seat of an aircraft built and maintained by somebody else whose proficiency you did not know, on the basis they had an L1 ?

Agreed - i'll jump into the rh seat of an aircraft not on the basis of the l1 of the pilot in the left if I do not know them but on the walkaround I did before getting in the rh seat ... usually i've had a good old chin wag with them first and if they own it they generally love walking around showing it off ... its how i have always operated and so far so good.

 

 

[M61A1]

Fortunately you don't rule the world; that statement beggars belief in 2016.

I disagree, and the fact that you feel it beggars belief says a lot about what is wrong with not just aviation in this country, but almost everything we do daily. The regulators , with their saviour complexes may feel they doing the world a favour, but like a helicopter parent with a child, it doesn't produce a good result.

 

 

[DonRamsay]

Fortunately you don't rule the world; that statement beggars belief in 2016.

Well, that was a bit dismissive Turbo. Not the usual analysis and searching logic I would expect from you.

The way I put it is as the opposite end of the spectrum to the current regulation-obsessed CASA approach. Hyperbole aside, this sort of thinking is beyond the capacity of a CASA to do. All you are likely to get is, as you did, instant dismissal. To change CASA from its current straight jacket mentality to a genuine service organisation would require emptying the building, moving to a much smaller building and starting from scratch.

 

I had a bit to do with the underground coal industry for a while. The only industry considered more dangerous at the time was timber cutting. The Coal Mines Regulation Act contained endless detailed regulation and it did not stop underground coal mines being extraordinarily dangerous places to work. People were being disabled or killed at terrible rate.

 

What caused a big change for the better in the safety record had not one single thing to do with more or tighter regulation, it came from engineering study and design. Continuous mining machines with integrated roof bolters operated remotely from a safe distance underneath bolted and supported roof and the expansion of longwall operations made the work underground enormously less risky.

 

The Act did change as well from insane detail like how thick the limestone dust had to be on the walls to something much closer to my global statement above.

 

So, yes there needs to be some regulation but it needs to be at the system level not the lockwire level.

 

 

[turboplanner]

Not interested in more waffle today.

 

 

[Keith Page]

Good on you Don you have mentioned something I have been on about for ages. You have seen this with your own eyes and how easy it was get implemented.. #117.

 

We do not need more Acts, Regulations and Rules to control things like what is being presented and designed currently.

 

In our case (RAAus) it is a simple case of Education and Culture development, this will be a simple shift to people being happy to belong and interested in helping. This is done without fluff, glitz, flowers and bells and whistles.

 

What will Acts, Regulations and Rules is only resentment and that is the direction at the moment.

 

Education and Culture development is not achieved with a big stick, Education and Culture development has to be done correctly imperative, then E&C is contagious spread like wild fire.

 

Regards,

 

KP

 

 

[DonRamsay]

Not interested in more waffle today.

Even more dismissive?

 

Good to see you have FT's support - you must feel good about that.

 

 

[facthunter]

Waffle or wisdom is in the eye of the beholder. One mans meat is another mans poison.. Nev

 

 

[turboplanner]

There's also fact and fiction

 

 

[DonRamsay]

There's also fact and fiction

No, that's reserved for the Atheist Knowledge thread.

 

 

[facthunter]

When objectivity is not much in evidence, Fact is what one says and fiction is what others say. Nev

 

 

[jetjr]

Followed this up a bit

 

It was an exercise in seeing how many aircraft are compliant with existing records requirements. Many reckoned we were all doing a good job.

 

Around a quarter replied to the request at all despite reminders, calls etc.

 

Very few of those who did reply were fully compliant with whats required. Like 2%. Pretty sure it included L2 serviced aircraft too.

 

It has come up as a result of lacking adequate maintenance records and poor standards when things get to CASA level or even it all goes legal for some reason.

 

This is a serious issue if we want to keep current maintenance freedoms - there are those out there that are looking for excuses to remove them.

 

The recommendation to cancel self maintenance can come from a magistrate who doesnt really get it, not just CASA.

 

The outcome is further education and clarity in whats required currently (and always has been) we just been ignoring it.