Part M - important news for owners/ operators

[jxk]

Hobby horse dismount.

OK, so what's to stop with a two man business: op 1 doing the maintenance management on aircraft A and op 2 doing the physical part and then op 2 doing the mm on aircraft B and op 1 doing the spanners bit. Seems like a real waste of time. This is all going to cost owners a hell of a lot of more money and drive GA further into the mire. It seems that creating this two tier system is another way for those who don't want to get their hands dirty to sit in office and make money. Part M seems over beaurcratic and what are facts to support this way of working: is this going to make continuing airworthiness any better, I don't think so. How many incidents are down to maintenance; usually manufacturing design problems eg valve, cylinder and casting failures.

[vee-tail-1]

Hmmn probably the only way to make sense of it is to read the French original.
The English version is clear as mud. Possibility for confusion: The French for maintenance (as in servicing) is entretien. The French for maintenance (as in continuing airworthiness) is maintien, and this is used a lot in part M. The French have also adopted the English word maintenance as in "organismes de maintenance" which refers to "operations d'entretien" A CAMO in French is "l'organism de gestion du maintien de la navigabilite"
Sorry I am not trying to be clever, it's so difficult to actually understand what the intention of part M is when the wording is so convoluted.

We have a French forum on pprune, I wonder if our French colleagues understand Part M better?

[giloc]

I agree that much of Part-M is close to impenetrable, but I think M.A.707 is actually pretty clear. In fact, it makes sense to me that the person conducting an airworthiness review should not have been involved in the maintenance management, since what they are reviewing is largely the documentation for which the maintenance management person has been responsible. Otherwise, they would essentially be reviewing their own work.

[jxk]

1. But why is supervising your own work bad? Currently, you have to sign for your own work anyway and are thus responsible for it.. Who will be responsible in future the manager or the mechanic? And if say an owner has done some work on their aircraft and you sign the aircraft off subsequently, who's responsible then?

2. It's very interesting to read that there appears to be a difference between the English and French interpretation of some of the terms used in Part M.

[EGBKFLYER]

Dear All,

I agree that the wording of AMC MA707 is not the best and reading it again v your commments made me wonder what the situation is really.

I've just got off the phone to one of my CAA surveyors, who has clarified it for me:
AMC MA707(4) says:

To hold a position with appropriate responsibilities means the airworthiness review staff should have a position in the organisation independent from the airworthiness management process or with overall authority on the airworthiness management process of complete aircraft.

The bold bit is the key. So far as CAA is concerned, they interpret this as meaning the Airworthiness Review Staff should be EITHER independent OR fully responsible - i.e. no halfway house. I already have one Subpart G approval under my belt done on this basis (CAM is also the only ARS), with another to follow in Sept, so it seems that is really how things are being seen.

Hope that helps! I love European legislation.

[vee-tail-1]

Thanks EGBK
only another 457 pages to dicipher

[IO540]

What would really interest me (if I was flying a Euro reg plane) is how easy/difficult it will be to get a 1000-1999kg plane maintained by a freelance engineer.

They are generally the best people for getting a decent job done (because the buck stops right there) and this is one of the advantages of N-reg ownership. It's easier for the owner to be pro-active on maintenance and use different people for different tasks according to their different skills and honesty.

[giloc]

I still don't see why M.A.707 is so hard to interpret. It actually gives a list of examples of what "independence from the airworthiness management process" means. One of those examples is the case where the engineer that does the maintenance also does the airworthiness review.

[giloc]

Originally Posted by IO540

They are generally the best people for getting a decent job done (because the buck stops right there) and this is one of the advantages of N-reg ownership. It's easier for the owner to be pro-active on maintenance and use different people for different tasks according to their different skills and honesty.

I agree. That is how I currently maintain my aeroplanes, and how I would like to continue to do so under Part-M. Assuming the latest EASA amendements are passed in to law, and non-commercial use, I'm hoping it will work like this:

I, the owner, am responsible for the airworthiness management of my aircraft.
I engage a Part-66 licenced, independent engineer to carry out the maintenance required under the LAMP.
Every year for aeroplanes >1000Kg and <2000Kg, and every third year for aeroplanes < 1000Kg I need to take the aeroplane to a CAMO with sub-part I privileges.
The CAMO conducts an airworthiness review and recommends the re-issue of the ARC for another year.
For the <1000Kg aeroplanes my Part-66 engineer conducts the 1st and 2nd year airworthiness reviews.
The CAA re-issues the ARC on the basis of the CAMO/engineer recommendations.

Part-M calls this an uncontrolled environment, but in reality I'm doing the controlling.

[EGBKFLYER]

Giloc,

Sounds OK to me.

A couple of points - CAA are saying LAMP is not enough. A maintenance programme has to be developed (MA302), which includes the manufacturer's recommendations, ADs, SIBs, SINs, SBs etc etc. LAMP will be a good base on which to build but doesn't include all the sources of data 'they' want to see. As an owner, you can also add things to the programme (e.g. a more regular spat inspection for operations off rough surfaces)

As the aircraft is outside the formally -defined 'controlled environment', each review will be the 'full' version (i.e. not just an extension). I guess time will tell how expensive that is compared with being in a controlled environment.

[giloc]

A maintenance programme has to be developed (MA302), which includes the manufacturer's recommendations, ADs, SIBs, SINs, SBs etc etc

Indeed, but this is no different from what we have in place already. And it helps that once the LAMP has been customised by the owner/operator for an individual aircraft it can then be considered CAA approved without any requirement to submit it for formal approval.

I guess time will tell how expensive that is compared with being in a controlled environment.

Exactly. However, hopefully a fair amount of competition will emerge in this area from new organisations, including from some in France.

For my aeroplanes I am expecting that no more than a day's work for each will be required to complete an airworthiness review.

[vee-tail-1]

EGBK giloc The CAA won a BIG concession from EASA when they renamed LAMs and called it LAMP. LAMP is a generic maintenance programme, and the French system on which part M is based uses Type Specific Programmes. These programmes are issued by aircraft manufacturers and are specific to mod state, engine type, equipment, ADs, etc. They use the ATA 100 numbering system and are intended to be used by owners as well as non licensed people. So they say EXACTLY what has to be done and when to do it, and require no interpretation. So any competent mechanic can achieve full and safe servicing of the specified aircraft. If you operate a French manufactured aeroplane the type specific maintenance programme for your aircraft will be on file with GSAC, and may well be available in English from the manufacturer.
This use of Type Specific rather than Generic is quite a cultural change for Brits.

[giloc]

Originally Posted by vee-tail-1

If you operate a French manufactured aeroplane the type specific maintenance programme for your aircraft will be on file with GSAC, and may well be available in English from the manufacturer.

I have a French manufactured aeroplane, and I have the English version of the maintenance manual. I don't like it, and I use the LAMS/LAMP instead. The main problem with it is that it makes assumptions about the level and type of utilisation that are not appropriate to my operation. The LAMS/LAMP allows a level of discretion in deciding what should be done and when, that I think is better suited to the hugely variable operating conditions that may apply to a particular GA type.

[EGBKFLYER]

Vee-tail. One of the companies I work with has a number of Robins in its scope of work - I'll make them aware of the GSAC thing (we have the luxury of access to a fluent French speaker too) so it may help. Thanks for the info.

Giloc - agree re the maint progs but under the old system, I wonder howm many folks actually amended LAMS to suit their own requirements?

[A and C]

Owner independence

One of the biggest problems with EASA part M is that once committed having the aircraft maintained by a sub-part G & F company the owner is more or less committed to stay with them or step out into the "uncontrolled environment" and face more expense.

This is a recipe for commercial disaster with company's giving poor service because they have the aircraft owner over a barrel and unreasonable owners claiming that engineering companies are abusing there position to generate work.

For this reason we are setting up a sub-part G company to manage aircraft maintenance for owners, this way the aircraft owner can take the aircraft to any sub-part F company for maintenance and stay inside the controlled environment.

It will also rid the part F company of 99% of the paperwork and give them an independent person to deal with the more unrealistic expectations of some owners.

I will announce the company in the aviation press once the EASA approval is in place.

[EGBKFLYER]

Good luck with that A and C - I wonder how many others will do the same?

[NutLoose]

It was going to be that the Engineer certifying the ARC would have been an independant Engineer within the company or that of a separate company such as happens now with Airlines.

But I believe it was realised that this would be untenable for one man Companies or those stuck out in the back of beyond to attain this...... The CAA would of had to attend those companies in the likes of the wilds of Scotland, and they simply do not have the staff to do that.

We original looked at having a Company on the next Airfield carry out our ARC issues and I would return the favour.. but was then informed that it would be ok for me to both Issue the ARC and carry out the work on the Aircraft as well, and as such our approvals are progressing with the system set up to do it this way in agreement with the CAA.....

So yes you can have one person responsible for both, after all is that not what we have already? the CAA previously issued the Certificate of Airworthiness based on the say so of the Nominated Engineer, who would possibly have also carried out the work required, without in 99% of cases ever seeing the Aircraft involved.

All the new system does is takes the CAA further out of the loop whilst further reducing their greatest fear....... Getting Sued

[jxk]

Why couldn't owners be asked what kind of maintenance organisation they would like? I assume that owners will still be ultimately responsible for seeing that their aircraft is airworthy. AND, if I were a Part G (nuts & bolts) I would expect the Part F to put their signature on the work as it will be them who decides what should done.

[NutLoose]

jxkWhy couldn't owners be asked what kind of maintenance organisation they would like? I assume that owners will still be ultimately responsible for seeing that their aircraft is airworthy. AND, if I were a Part G (nuts & bolts) I would expect the Part F to put their signature on the work as it will be them who decides what should done.

Actually I think you are misreading the rules..... All the part F does is releases the Aircraft back to service and determines the minimum requirements of that work...... they neither carry out the survey as such or sign for the work carried out on the aircraft, the simply oversee and manage the check.... true they may clear it after inspecting it and issue the ARC, but the Licenced Engineer that has signed for the work under Part G is still ultimately responsible for the work he has carried out. And that is where the buck will eventually stop... so regardless of what the part F maintenance company says, I would never sign an aircraft off I was not personally 100% with.

[IO540]

I must confess this stuff goes way above my head. I went to a presentation on Part M a while ago and it went over my head then too. Reading about it now, and having spoken to a few maintenance firms recently, it is obvious that interpretations of the regs vary so widely it is a bit of a joke at times.

The one thing I do understand however is airfield / maintenance politics. Whatever system is adopted it needs to be realistic. Currently, many (many) owners do not use the company based on the airfield for various reasons. It might be no good, or it might be OK but you cannot give them any work (other than trivial) in case there is a dispute in which case you will have trashed the one band which can give you a release to service signature in an AOG situation.

My experience is that the happiest owners who keep their planes in the best condition are ones who have the freedom to pick and choose who does what (and yes a disproportionate % of those are N-reg because doing exactly that is easier on the N-reg). I am one of these but it took a while to suss things out.

Large chunks of the maintenance scene are nothing short of a disaster, but if you are not careful you will end up over the barrel belonging to one of these companies.