EASA money pit

[ericferret]

Did company approval work well under the CAA?

Examples.

1)Engineer X fails the UK engineers licence, his employer a major UK operator then gives him full company approval without any form of examination or retraining.

2) Same company then gives full approvals to other engineers without licenses (again with no examination) and advises them not to sit the licence exam as it might cause problems.

Can you imagine the outcry if this had been pilots and not engineers.

The CAA then changed the system so that a basic licence was a requirement to hold company approval. So in effect holders of approvals were still licensed engineers.

[A and C]

DFC one more time you show how little you know of the system !

Yes it is quite correct that that all the airlines in the UK do the certification of maintenance via an approval system, that is because they would not issue a type rating for an aircraft under BCAR 8-13.

However it was a requirement to have an engineers licence (without type rating) befor you could go on the approved course to get CRS approval.
To give some sort of idea the course for the Airbus A320 airframe & engine lasted nine weeks. Without this you could not certify a duplicate inspection.
In all the UK airlines that I have worked for (five in all) I have never seen anyone who was not a licenced engineer carry out a duplicate inspection except in componant workshop and that comes under a different approval system.

As to light aircraft I can only think of a few places that non-licenced staff can certify a CRS and they have major overhaul approval for very limmited tasks.

At NO time in this business (30 years) have I seen the CAA "ignore" the requirement for a duplicate inspection on flying controls Etc.

[DFC]

Yes but a 3rd year apprentice can get a Basic Licence. i.e. They have the licence before completing the apprentiship!

I don't think that there was ever a case of;

a major UK operator then gives him full company approval without any form of examination

Yes there were people with company approval who failed the licence. However, there was an approved training system in place from apprentiship through to shop floor in order to get the approval.

OK you could argue that if one had company approval on the B737 then obtaining a basic licence and adding a B737 type should be easy.....but for some, 10 to 15 years after apprentiship, it took quite a bit of work to pass the theory element of the Basic Exam.

None of Us can remember the finer points that we learned and passed tests in at 19 or 20 years of age.

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A and C,

I'll ask again. Please give us all the details of the proposed EASA duplicate inspection scheme that you find such a problem with.

As for aircraft under CAA with no duplicate inspection - how about those that one can remove the wings from for road transportation. No requirement for duplicate inspection (very hard at times to find another person in a field in the middle of nowhere).

If the CAA thought that there was such a requirement then it would apply to among other fixed wing categories as microlights including the skyranger that ended up in a tragic accident some time back doe to misrigged controls.

Not all aircraft are required by the CAA to have a duplicate inspection. You should know that.

Again - please explain the EASA duplicate inspection process and wht exactly is dangerous.

Regards,

DFC

[A and C]

DFC

I will have to go deep into the books for the EASA duplicate inspection details and I don't have then here now as you won't be happy untill you get this chapter and verse.

Aircraft that are intended to be de-rigged have never required a duplicate inspection after rigging but these systems are built to be "idiot proof" (unlike this forum!). However even a de-riggable aircraft has to have duplicate inspections on the flying controls if they are disconected in any way apart from that in the POH.

You are showing how out of date you are with the maintenance system as you are correct that you could get an engineers type rating on the B737-200 but it was the last big jet airliner that the CAA would issue a type rating on.
From the mid seventys the CAA would only allow large jet transports to be maintained under a BCAR 8-13 approval so as I said above it reqired an engineers licence (without type) and a company approval to certify the CRS.

So even if an engineer had a type rating on a B737-200 by the 80's he could not certify a CRS without a company approval for the type.

Microlights are not part of the EASA system and so should not be included in this thread.

[DFC]

Microlights are not part of the EASA system and so should not be included in this thread

They are CAA approved aircraft operated under the CAA oversight and do not need duplicate inspections.

I am not saying that is safe but the CAA does permit aircraft to fly without duplicate inspections. In one case (the Skyranger I mentioned) misrigging resulted in a fatal accident.

-------------

I will have to go deep into the books for the EASA duplicate inspection details and I don't have then here now as you won't be happy untill you get this chapter and verse.

But as an Engineer, you should know that without having to look it up should you not. If not then how can you say previously........

What I am tyring to make clear to DFC is EASA Part M only brings lots more paperwork and CAA charges, you don't get is any extra "hands on" maintainence and in the area of duplicate inspections of flying controls and other critical systems the EASA system is a real errosion of safety standards.

(My highlighting)

........When here you say that you do not know what the EASA requirement is.

Clearly a case of EASA bashing or simply trying to make excuses to those pilot that either don't know better or fail to question such claims.

Regards,

DFC

[A and C]

DFC

IF you are so sad that you can commit to memory all the EASA part M chapter and paragraph numbers so be it, As I said you won't be happy unless you have chapter & verse.

I am paid to have a broad understanding of the leagal side of maintainence and a much deeper understanding of the technical side but most important I have the nouse to know when to commit something to memory and when to go look for something in the manuals!

I for instance would not rigg a flying control system without the aircraft manual in front of me, dispite the fact that I might have done the job a number of times before, Its a safety thing!

So now you go tell the world that I can't can do my job without the books to tell me how to do it!!

[A and C]

DFC

You will find the full details in EASA part M M.A.402. (acording to CAA publications).......... I have not had time to check it myself as I have to spend all day changing the LAMS paperwork to LAMP.................. another unproductive day!!

And before you tell me I am behind the drag curve the implimentation date is 28 September 2008.

[DFC]

A and C,

OK I can see it clearly now.

You said;

and in the area of duplicate inspections of flying controls and other critical systems the EASA system is a real errosion of safety standards

Which can only be said if one has actually read or otherwise has knowledge of the requirements for duplicate inspections.

However, you now say;

I have not had time to check it myself

Which says that you have not seen and do not have knowledge of the requirements.

Thus you can not say that the requirements which you don't know are unsafe now can you?

Regards,

DFC

[A and C]

DFC Deliberatly thick!

I have not actualy checked the LOCATON of the duplicate inspection requirements today.

I can assure you that I would not comment on the subject if I did not have some knowlage of the subject, the duplicate inspection or Independant inspection as EASA call it was initaly raised a t CAA part M meeting.

DFC so far all you have done deliberatly misinterpret all that I have writen and push your own out of date and misleading view of engineering practices and the cost of doing business. It is not posable to have a reasonable exchange with you because you are to busy trying to score points and push your own slanted agenda.

I suspect that you were one of the "old guard" of pilots who looked down on engineers as a lower form of life and resents having to pay to have your aircraft maintaned by "lowlife" who in your opinion are clearly ripping you off.

Well I have news for you, flying a jet airliner is not reason for you to be considered a skygod or the font of all aviation wisdom and you have clearly demonstrated this to a number of the people in this forum.

Oh............by the way flying a jet airliner can't be that hard............ a number of us engineer lowlife do it as a hobby to relax from "real" work!!

[ericferret]

Well DFC the subject of engineers holding approvals who had failed the licence was the subject of a crewroom conversation only a couple of days ago. A number of us remember it well and could name names if necessary

Approvals were dished out on the basis that X was a good egg. There were no formal examinations of any kind.

This was why the CAA changed the system to make it a requirement to hold a basic licence.

You appear to have a British Airways hat on with talk of apprenticeships. None of the engineers in question had been trained by the operator they were all "imports".

[ericferret]

On the subject of current company type approvals.

All that is now required under the current system for an engineer to be able to certify on type is, Basic licence, pass the type course, 2 weeks OJT and the company approval is a paper exercise.

[DFC]

Thanks for the insults A and C. Pleae note that I refrain from acting in kind and since you do not know me, you do not know how wrong you are top say;

"I suspect that you were one of the "old guard" of pilots who looked down on engineers as a lower form of life"

However, you are the one who said that the EASA proposals for duplicate inspections were dangerous but you do not know what they are.

Don't make claims that you can't back up simply to try and excuse inflated pricing or simple EASA bashing because it gets you no where.

Regards,

DFC

[A and C]

DFC

Clearly you don't read anything I said that you would require chapter and verse to shut you up and that I did not have that to hand at that moment NOT that I did not know what the EASA regulations are.

The basics of it is that a company can approve anyone that it thinks is fit to do a duplicate or (in EASA speak) independant inspection.

At the moment it is very unusual to find anyone who is not a licenced engineer who has duplicate inspection approval.

A duplicate inspection is a very hard thing to do not so much from a techincal point of veiw but from a human factors stance, the person comes to the inspection knowing that a licenced engineer has already inspected the job and is more likely to start with tha assumtion that all is correct.

If the person with the duplicate inspection approval is a non-licenced junior member of staff and the job has been done by the Chief engineer it is likely that he will feel uneasy about expressing doubts about the job, this is a lot less lightly to happen if a licenced engineer is doing the duplicate inspection as his status in the company will be a lot higher as well as having a lot more experience in engineering.

There is some psyco-babble to discribe this but I cant put my finger on the term right now................... Oh no ! DFC is about to demand that I go on a CRM refresher course!

[DFC]

OK A and C, since you don't know the requirements, let me explain them to you. They are very simple.

The first independent inspection is completed by a person qualified to complete the task and also qualified to certify the work. This person certifies the work.

The second independent inspection is completed by a competent person who does not need to hold certification privileges since they are not signing the maintenance release.

However, the mainrenance organisation has to have procedures to show that the person performing the second inspection has been trained and has gained experience.

It is not acceptable for the person signing the release (the first inspection) to show the person making the second inspection how to perform the inspection at the time it is completed.

Now to me, there is nothing new there. The second inspection must be completed by a previously trained and competent person who is familiar with the system.

Is that dangerous. If the answer is yes then the system currently used in the UK is dangerous and has been for many years.

Not much is changing. No excuse for a moan or a hike in prices for competent organisations that keep abreast of developments.

Regards,

DFC

[Malcom]

EASA Part M.Subpart F, G, I.
All in all, an eminently workable system for GA. 50 hour done in a morning - no problem.
Scenario A - Today,
Owner flys, updates his logs & finds he now needs a 50 hour.
- Goes to local M3 who do the 50 hour. Fix something broken if needed, cos they have data to hand.
--Goes flying again.
Scenario A costs to the owner are
: a 50 hour + defects.
Scenario B - EASA Part M. September 2008 (– maybe?)
Owner Flys. Tells CAMO who update his logs. CAMO finds he needs a 50 hour.
- CAMO tells owner he needs a 50 hour.
--CAMO tells Maintenance Organisation (MO) owner needs a 50 hour.
---Owner tells MO he needs a 50 hour.
----Owner arranges with MO to do 50 hour.
-----Owner tells CAMO 50 hour will be done.
------CAMO provides MO with data to do 50 hour.
--------MO does 50 hour.
---------MO tells owner something broken
----------MO tells CAMO something broken
-----------Owner tells MO to fix something.
------------Owner tells CAMO something will be fixed.
-------------CAMO provides Data to fix something.
--------------MO tells owner something fixed.
---------------MO tells CAMO something fixed.
----------------CAMO tells owner something fixed.
-----------------MO tells CAMO plane ready
------------------MO tells Owner plane ready.
-------------------CAMO vets MO stuff.
--------------------MO tells owner to go flying.
---------------------CAMO tells owner to go flying.
Owner too poor / tired / exasperated / to go flying now. Gone sailing / kiting / something else instead.
Scenario B costs to the owner are
: a 50 hour check + defects
: MO maintenance contract involving provision of staff, facilities etc at a time that suits both parties.
: CAMO Contract, provision of qualified staff, approved data etc at a time that suits both parties, time spent auditing CAMO.
: CAMO time spent passing additional data to MO for defect rectification, on a prompt basis
: downtime while all this extra stuff is going on
: + I’m sure there’s more
Please explain how this makes flying safer and makes the hobby cost effective.
The owner remains responsible in both cases, so no change in responsibilities.
Then please also explain how this makes flying safer for aircraft to which EASA has no remit?
Sympathising wholeheartedly with A & C, I take issue with DFC and his rather rosy view of EASA.
DFC wrote
"If you simply want to continue to provide maintenance then there has not
been any significant increase in costs. If you want to provide extra services then there
will of course be extra costs involved in gaining the extra approvals".
---The above scenarios possibly demonstrate that no extra services are provided, at increased cost – the aeroplane flies, has its 50 hour, goes flying again. The same service is accomplished via yet another management level - the CAMO.
DFC wrote
"Did you just discover EASA part M etc last month. I seem to remember it being common knowledge (if not in final form) for almost a decade."
Well, you said it - not in final form.
Exactly what system should be set up when there is nothing to base the set up on?
Do we set up with a CAMO, or will we not need a CAMO??
Will the controlled environment remain as proposed or not be required for planes below 2000 kg??
MDM032 – not very helpful yet.
As you are in Euroland, you are probably unaware of the UKland's current state of not knowing whats going on at the moment. We find ourselves shortly having to be in compliance with something not finalised yet, and all done before by 28-9-08.
DFC wrote:
"So sit in your office and put up your prices.....remember that the cost of approval represents very few hours at UK engineer rates....what do you do with the income from all the other hours income? Don't complain when other maintenance organisations get your work."
Who is this bloke? Put up my prices - other maintenance organisations will get my work.
He clearly doesn’t live or work in the UK. The other Income now seems to pay Independent Auditors, time spent self auditing, redoing Maintenance programmes in whatever the latest fashion is, hunting for basic information on the CAA & EASA websites, reviewing the lasted Ads, SBs, MMs, IPC, Screwfix catalog, incorporating mandatory modifications in the UK which are seemingly not required elsewhere in the EU, removing these mods when the plane is sold back to the USA, getting LAEs converted from BCAR to Part 66 with types the CAA don’t seem to know about (eg metal planes made of wood), drafting repairs & mods for approval by someone in Euroland, progress chasing such things, ………………………and eating.
Forgot about actually doing some maintenance work to generate said income – cant believe I did that!
I know what to do – I’ll put up my price to £ 50/hr, then Mr Eastern European wont get a look-in at his £ 15/hr plus European grants and other stuff. Better still I’ll move to China, you can fly there and have your 50 hour at £5/hour. At that rate I wouldn’t dare complain if my work went elsewhere!
DFC wrote|:
"I can pay a UK engineer £60 per hour or I can pay a French one EUR60 for the same product i.e. EASA certified maintenance. That is a big difference when it comes to certain scheduled maintenance."
Earlier, you suggested putting up prices. Why recomend I put up my prices when I'm already more expensive? Is this part of a cunning plan?
Anyway, I'm off to Cuckoo-Land to get £60/hour working on PA28s - I need directions as my map shows (mostly) the real world. Could I borrow your copy please.
If I were to take a plane from the UK to France for maintenance, the saving between £60 and 60 euro in France might just be eaten away with transit fuel and en-route landing fees and hotel fees when stuck abroad due weather and time off work to do the trip or paying someone to do this for you or getting back when you cant fix something for a few days or weeks or months awaiting spares or EASA repair approval.
DFC wrote|:
"There is absolutely no reason for club training aircraft to be certified for public transport.A point hopefully EASA will pick up on."
Read the MDM032 update
(The 2 monthly update of the July one has just been issued by EASA this month - December)
Interesting comments about commercial activities contained therein!
Club training for free - yes please.
DFC wrote|:
"If the aircraft can not go to the maintenance organisation then the maintenance organisation can come to the aircraft."
Interesting thought. I was led to believe the idea was to remove the back of the car engineer from the system by having approved sites & facilities & staff.
How does that stand with MA402 and a PA28 in the middle of a cold, wet & windy airfield? (Would only happen in the UK only, of course)
DFC wrote about costs:
"I know one club in the South of the UK who lease hangar space to a local UK maintenance organisation that then charges thema fortune for crap maintenence. The club could take control of it's own maintenance and that of many local owners and do a far better job of it than at present."
That club probably don’t want to, or can’t afford to take on the cost of full time engineering staff, fund the approvals required and have no work. Crap weather= no flying+ staff to pay+bill to pay= financial disaster. (UK only, of course).
Is saying something about crap maintenance a wise thing to say in these litigious times?
DFC wrote about Duplicate Inspections:
"If the CAA thought that there was such a requirement then it would apply to among other fixed wing categories as microlights including the skyranger that ended up in a tragic accident some time back doe to misrigged controls."
The CAA oversees the BMAA. The BMAA does have such a requirement.
DFC wrote about Duplicate Inspections:
“But as an Engineer, you should know that without having to look it up should you not. If not then how can you say previously........”
Under EASA, just knowing something is totally unacceptable - you must always be in a position where you are able to refer to basic and detailed Information. (MA401).
" please explain the EASA duplicate inspection process and wht exactly is dangerous."
as explained by A&C, using a second licensed engineer is superior to using anyone deemed competent by a company who may, if they so choose, use the tea-boy for the task. I would agree use of the Teaboy for Duplicate Inspections is unacceptable and potentially dangerous.
DFC wrote about Engine lives:
“Of course, while the CAA may think otherwise, EASA does not think that if Lycoming or Continental say that the engine they designed, built and had certified is good for 2000 hours or 12 years whichever is first and then requires an overhaul..........then one can still call the engine a certified engine with 15 years since overhaul.
I would love to have an aviation authority like that.”
Well, we had that Aviation Authority until recently. Airworthiness Notice 35 / GR24 worked well until the calendar TBO RECOMMENDATION was too rigidly enforced, unlike in the relevant Service Bulletins which give some leeway. Under this system I have happily & confidently flown 3500/4000 hour Lycomings – I thought nicer than newer ones, and were much better looked after under the extension criteria.
Anyway, got to get redoing LAMS as LAMP for some of the planes, but not all of them, or shall I leave it as it might change to manufacturers schedules in January 2008 or September 2008??
Just got a LAMP addressed to the owner of an Annex II type?
Does anybody know what’s going on?? Perhaps its all just a giant EASA HF test just to see how well we can cope with being dangled by the b*******s??

[A and C]

DFC You seem to have avoided the issue one more time and are just showing how out of date you are with the CAA system. unfortunatly I can't write it in large multi-coloured wax crayon but I will try to make it clear.

Under the CAA system almost all duplicate inspections are done by licenced eneineers. EASA reqires the maintenance company to use a competent person

This is a change as under the CAA system a duplicate inspection is a CRS item.

[SIZE="2"]The CAA did go down that road for a short time but the systen was being abused so stopped it in the mid 70's[/SIZE

EASA is about to repeat a thirty year old mistake and you clearly are to blinded by your own out of date view to see that this is an errosion of standards

[A and C]

Malcom

Thank you for that post it clearly sums up the situation and hopfully will put that DFC half wit back in his box.

I rather lost all respect fo the guy's point of view and the tunnel vision has decended following a day on front of the computor writing the individual "customised" LAMP workpacks that the CAA are demanding for each aircraft we look after............... another day of unprodutive pen pushing!

[DFC]

A and C,

You just do not get it.

If a person is competent, then that is it.

There are quite a few licensed engineers that I would not call competent.
I like the way you are inventing work for yourself.

Perhaps it is the CAA's fault for asking you to produce things that toy should have had all along.

---------

Malcolm,

You need to read the requirements again. Even those CAT operators who operate several fleets do not have to go through all that.

The BMAA does not require duplicate inspections. It does recomend them in certain cases.

If I want to I can take the wing off a microlight and dismantle the wing, put it on a trailer, travel to a field in the middle of nowhere reassemble the wing and put the wing back on the aircraft then go flying. I can do that solo with no contact with any other person and the permit to fly remains valid.

Regards,

DFC

[A and C]

It,s all becoming so clear

DFC I am constantly amazed the dispite at least two people who are directly involved in trying to make this EASA part M fiasco work you insist that you know better.

I can't understand why you keep banging on abou microlights these low energy powerd kites have nothing to do with the EASA part M system.

The bottom line is the EASA part M is going to cost a lot of money to introduce and at best will do nothing to improve safety.

The result is that I expect by September 2008 a number of engineering busnesses with shut cutting the supply of maintenance, aircraft owners will find it harder to find maintenance and the price will increase purly because of the laws of supply and demand.

The only people to loose out will be the owners of aircraft who will have to pay up or stop flying.

But to look on the bright side at lease those of us who survive the dark days to come will be able to charge more for the services that we provide and recover some of the time and money spent introducing EASA part M.

DFC I look forward to one the day when EASA part M hits you very hard in the cheque book, only then will it dawn on you that Malcom and myself were right all along.

[Fuji Abound]

I have been following this debate with interest.

DFC

Without mention of micro lights can you explain in concise terms what advantages in either safety or cost part M will bring?

A and C

What ever happened to the regulatory impact assessment with regard to these changes?