Part M - important news for owners/ operators
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Part M - here it comes, ready or not
I have read this thread with great interest, not just for entertainment, but like most of us on here, this place is one of the better areas to get helpful and factual information. Our ever-helpful Civil Aviation Authority haven't been too good at disseminating information to aircraft owners/operators in recent years, especially regarding Part M Sub Parts G and I. Their standard response is still 'well, it is on our website'.
For personal and professional reasons, the 28 September 2008 will have an effect on me. As well as owning/running my own Part 145, I am also an aircraft owner.
You could be forgiven for thinking that because of my association with professional and approved maintenance, I would have all the knowledge required to move smoothly forward with Sub Parts G and I. Well, actually I am quite uncomfortable with most of it, for what I consider good reasons.
With regard to my AOC commercial customers, I feel that Part M Sub Part G is right. If you are carrying passangers for hire or reward, then the standards of operation and maintenance must be of the highest order. I have no problem whatsoever with this notion. The extra level of administration is even, in my humble opinion, justifiable, providing all EASA AOC operators are subject to the same, stringent requirements. No exceptions. No exemptions. The utopian level playing field. After all, that is what we all have been told will be happening.
To take stringent, restrictive, and financially burdonsome commercial requirements, drawn up around the airline industry, and force them onto non-commercial light aviation is not right, nor is it appropriate.
For many years, non-commercial light aviation has been maintained and certified by professional and well motivated engineers. Within an organisation, one appropriately licenced and approved engineer has been able to raise all paperwork, clear and certify that paperwork, issue a CRS, complete Log Book entries, update the history file for the aircraft, and for non-commercial 'Public Transport' type operations such as flying school aircraft, issue a Certificate of Maintenance Release or CMR. The CMR is a statement from the engineer confirming that over the last three to twelve months (as applicable) all appropriate maintenance and mandatory inspections and modifications have been carried out and complied with.
It has now been deemed that the sole certifying engineer can no longer be trusted with this responsibility. EASA wants the three tasks, a) raising and recording of workpacks and history files; b) certifying aircraft by issuance of CRS; c) issuing the CMR under a new name - Airworthiness Review Certificate; all to be carried out by three seperate individuals. And they wanted all three to be licenced engineers or graduates. This scenario is straightforward for the airlines with large admin and tech record departments.
The authority has made noisy complaints about the light aviation industry not having acted yet, being as they have had four years to prepare and apply for Sub Parts G and I. The authority hasn't, however, listened to the same industry who advised said authority that, following the fiasco of JAR's the industry would wait until the 11th hour as the authority would, without fail, move the goalposts. As we all can see following recent events, letters and LTO's, this is exactly what has transpired.
The CAA became so concerned that the industry wasn't bothering to apply for Sub Parts G and I that they even reduced the initial application fee - to £41. They have also stated that for the smallest organisations, one individual may carry out all three tasks. The CAA are making loud noises about the 160+ Part 145 Approved Maintenance Organisations that have now applied for Sub Parts G and I. The industry has told the CAA, all that is happening is organisations are merely registering an intent. If it is decided to be too administrativly and financially burdonsom, the industry will simply cancel their 'register of intrest' and write off what amounts to be less than one man-hour labour charge.
Is it too burdonsom?
From the financial point; for a small organisation, the authority will allow one person to carry out all three tasks. But because the Sub Parts G and I will be its own seperate approval, the CAA want paying for issuing and renewing this new approval. So in reality, the small organisation can continue to do what they have been doing for years, only now they will have to pay for the pleasure. The Sub Parts G and I will also have to have regular external audits in the same way as any other approved organisation, and this will have to be paid for. These costs will have to be passed onto the owner/operator. The Sub Part G, or CAMO (Continued Airworthiness Maintenance Organisation) will have to initially create a 'back-to-birth' history for each and every aircraft they will be managing. For a two-year old Cessna 172 or Piper Archer, this will be straightforward. Only most privately owned aircraft arn't two years old. How many of you have a thirty year old aircraft with only one or two Log Books going back ten years? How are you supposed to retrace the first twenty years of that aircrafts life? This initial investigation will not be cheap. Another cost to the beleaguered owner. These costs will have to be added to by ensuring your new LAMP meets the CAA requirements by the 28th of September 2008. How many owners/operators will be able to do this to the required standard without input from their maintenance organisation?
From an administrative point; there will have to be a new book raised by the Sub Part G detailing what they will be doing and how they will do it. This is similar to an MME or an MOE, and is titled a CAME (Continued Airworthiness Maintenance Exposition). This will have to be approved by the authority. The premisis for the Sub Part G, which literally can be a broom cupboard, will have to be approved by the authority. External audits will have to be responded to. Authority audits will have to be responded to. For an existing Part 145 approved organisation, this is a considerable increase in what is already percieved to be a grossly excessive beurocratic excercise which detracts from the original mission of maintenance of aircraft. This final point is seen by many small organisations as proof that light aircraft maintenance is less safe under EASA than under previous umbrellas. The stated reason for this is simple. It requires an experienced engineer to be able to deal with the ever-increasing reams of EASA generated paperwork. The more time this experienced engineer spends on paperwork, the less time he or she is able to spend on supervising maintenance. The professional and dedicated junior or less experienced engineering staff will continue to give their best, but the eye and voice of experience will not be there to advise them 'don't disconnect that yet or this will leak everywhere' or 'if you move this first, that will not get bent'. Experience isn't written down in the manufacturers maintenance manuals.
So, with regard to my earlier comment about my discomfort. After all this administration and financial cost, will any of it make your privately operated aircraft any safer? I suspect that my own personal views are sure to be echoed by many others here.
There is another point that has been brought to my attention recently by someone who has far more grasp of the whole Sub Parts G and I picture than myself.
At present, if the certifying engineer, who really is a human, misses an Airworthiness Directive or other mandatory requirement, the CAA will give him or her a hard time and advise them of the error of their ways. Official letters will be written and the lesson will hopefully be learnt.
Apparently, under EASA, if the Sub Part G and Sub Part I individual(s) miss an AD or other mandatory requirement...
it is a criminal offence.
So, following a human factors issue, a licenced engineer ends up with a criminal record. Now try and get a job in aviation with that behind you, especially in these times.
As an aside, the CAA's published list of Sub Part G approved organisations makes interesting reading, if only for the wrong reasons. Two thirds of the organisations presently approved are approved for either turbine aircraft or helecopters only.
Well, after digesting the above, how many of you will move across to the LAA or 'N' reg before January 2009? How many of you are going to be stuck with type certified 'G' reg aircraft that you can't sell and are too expensive to maintain? And how many of the Part 145's will actually follow up their 'register of intent' and gain Sub Part G approval?
Oh, forgot to mention, I haven't applied.
And, most importantly, do remember. A Continued Airworthiness Maintenance Organisation has absolutely nothing to do with maintenance. It is only an administrative organisation.
Real maintenance is carried out by engineering staff in a MAINTENANCE ORGANISATION such as an M3 or a Part 145.
camlobe
For personal and professional reasons, the 28 September 2008 will have an effect on me. As well as owning/running my own Part 145, I am also an aircraft owner.
You could be forgiven for thinking that because of my association with professional and approved maintenance, I would have all the knowledge required to move smoothly forward with Sub Parts G and I. Well, actually I am quite uncomfortable with most of it, for what I consider good reasons.
With regard to my AOC commercial customers, I feel that Part M Sub Part G is right. If you are carrying passangers for hire or reward, then the standards of operation and maintenance must be of the highest order. I have no problem whatsoever with this notion. The extra level of administration is even, in my humble opinion, justifiable, providing all EASA AOC operators are subject to the same, stringent requirements. No exceptions. No exemptions. The utopian level playing field. After all, that is what we all have been told will be happening.
To take stringent, restrictive, and financially burdonsome commercial requirements, drawn up around the airline industry, and force them onto non-commercial light aviation is not right, nor is it appropriate.
For many years, non-commercial light aviation has been maintained and certified by professional and well motivated engineers. Within an organisation, one appropriately licenced and approved engineer has been able to raise all paperwork, clear and certify that paperwork, issue a CRS, complete Log Book entries, update the history file for the aircraft, and for non-commercial 'Public Transport' type operations such as flying school aircraft, issue a Certificate of Maintenance Release or CMR. The CMR is a statement from the engineer confirming that over the last three to twelve months (as applicable) all appropriate maintenance and mandatory inspections and modifications have been carried out and complied with.
It has now been deemed that the sole certifying engineer can no longer be trusted with this responsibility. EASA wants the three tasks, a) raising and recording of workpacks and history files; b) certifying aircraft by issuance of CRS; c) issuing the CMR under a new name - Airworthiness Review Certificate; all to be carried out by three seperate individuals. And they wanted all three to be licenced engineers or graduates. This scenario is straightforward for the airlines with large admin and tech record departments.
The authority has made noisy complaints about the light aviation industry not having acted yet, being as they have had four years to prepare and apply for Sub Parts G and I. The authority hasn't, however, listened to the same industry who advised said authority that, following the fiasco of JAR's the industry would wait until the 11th hour as the authority would, without fail, move the goalposts. As we all can see following recent events, letters and LTO's, this is exactly what has transpired.
The CAA became so concerned that the industry wasn't bothering to apply for Sub Parts G and I that they even reduced the initial application fee - to £41. They have also stated that for the smallest organisations, one individual may carry out all three tasks. The CAA are making loud noises about the 160+ Part 145 Approved Maintenance Organisations that have now applied for Sub Parts G and I. The industry has told the CAA, all that is happening is organisations are merely registering an intent. If it is decided to be too administrativly and financially burdonsom, the industry will simply cancel their 'register of intrest' and write off what amounts to be less than one man-hour labour charge.
Is it too burdonsom?
From the financial point; for a small organisation, the authority will allow one person to carry out all three tasks. But because the Sub Parts G and I will be its own seperate approval, the CAA want paying for issuing and renewing this new approval. So in reality, the small organisation can continue to do what they have been doing for years, only now they will have to pay for the pleasure. The Sub Parts G and I will also have to have regular external audits in the same way as any other approved organisation, and this will have to be paid for. These costs will have to be passed onto the owner/operator. The Sub Part G, or CAMO (Continued Airworthiness Maintenance Organisation) will have to initially create a 'back-to-birth' history for each and every aircraft they will be managing. For a two-year old Cessna 172 or Piper Archer, this will be straightforward. Only most privately owned aircraft arn't two years old. How many of you have a thirty year old aircraft with only one or two Log Books going back ten years? How are you supposed to retrace the first twenty years of that aircrafts life? This initial investigation will not be cheap. Another cost to the beleaguered owner. These costs will have to be added to by ensuring your new LAMP meets the CAA requirements by the 28th of September 2008. How many owners/operators will be able to do this to the required standard without input from their maintenance organisation?
From an administrative point; there will have to be a new book raised by the Sub Part G detailing what they will be doing and how they will do it. This is similar to an MME or an MOE, and is titled a CAME (Continued Airworthiness Maintenance Exposition). This will have to be approved by the authority. The premisis for the Sub Part G, which literally can be a broom cupboard, will have to be approved by the authority. External audits will have to be responded to. Authority audits will have to be responded to. For an existing Part 145 approved organisation, this is a considerable increase in what is already percieved to be a grossly excessive beurocratic excercise which detracts from the original mission of maintenance of aircraft. This final point is seen by many small organisations as proof that light aircraft maintenance is less safe under EASA than under previous umbrellas. The stated reason for this is simple. It requires an experienced engineer to be able to deal with the ever-increasing reams of EASA generated paperwork. The more time this experienced engineer spends on paperwork, the less time he or she is able to spend on supervising maintenance. The professional and dedicated junior or less experienced engineering staff will continue to give their best, but the eye and voice of experience will not be there to advise them 'don't disconnect that yet or this will leak everywhere' or 'if you move this first, that will not get bent'. Experience isn't written down in the manufacturers maintenance manuals.
So, with regard to my earlier comment about my discomfort. After all this administration and financial cost, will any of it make your privately operated aircraft any safer? I suspect that my own personal views are sure to be echoed by many others here.
There is another point that has been brought to my attention recently by someone who has far more grasp of the whole Sub Parts G and I picture than myself.
At present, if the certifying engineer, who really is a human, misses an Airworthiness Directive or other mandatory requirement, the CAA will give him or her a hard time and advise them of the error of their ways. Official letters will be written and the lesson will hopefully be learnt.
Apparently, under EASA, if the Sub Part G and Sub Part I individual(s) miss an AD or other mandatory requirement...
it is a criminal offence.
So, following a human factors issue, a licenced engineer ends up with a criminal record. Now try and get a job in aviation with that behind you, especially in these times.
As an aside, the CAA's published list of Sub Part G approved organisations makes interesting reading, if only for the wrong reasons. Two thirds of the organisations presently approved are approved for either turbine aircraft or helecopters only.
Well, after digesting the above, how many of you will move across to the LAA or 'N' reg before January 2009? How many of you are going to be stuck with type certified 'G' reg aircraft that you can't sell and are too expensive to maintain? And how many of the Part 145's will actually follow up their 'register of intent' and gain Sub Part G approval?
Oh, forgot to mention, I haven't applied.
And, most importantly, do remember. A Continued Airworthiness Maintenance Organisation has absolutely nothing to do with maintenance. It is only an administrative organisation.
Real maintenance is carried out by engineering staff in a MAINTENANCE ORGANISATION such as an M3 or a Part 145.
camlobe
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Great post Camlobe. I think it sums up what an awful lot of people involved in GA are thinking. I'm hoping this thread will keep running and that owners and maintenance staff alike will post their experiences after 9/28 so we can all see if it's actually the problem we think it's going to be right now.One tiny point:
Continued Airworthiness Maintenance Organisation has absolutely nothing to do with maintenance. It is only an administrative organisation.
Real maintenance is carried out by engineering staff in a MAINTENANCE ORGANISATION such as an M3 or a Part 145.
Real maintenance is carried out by engineering staff in a MAINTENANCE ORGANISATION such as an M3 or a Part 145.
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Camlobe
A great post: I believe most owners are completely oblivious to these changes. And although the initial issue fee of £41 is a one off, what about the future; I've heard figures of £2700 for each part (F & G). So, if true this adds £5400 to the costs of an average M3 organisation, FOR WHAT?. Grrrrrrrrrr!
A great post: I believe most owners are completely oblivious to these changes. And although the initial issue fee of £41 is a one off, what about the future; I've heard figures of £2700 for each part (F & G). So, if true this adds £5400 to the costs of an average M3 organisation, FOR WHAT?. Grrrrrrrrrr!
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Another 'well done' for Camlobe's post from me. I passed on some of the info from this thread to my (Gatwick-based) surveyor and he's gone off to compare notes and find out what constitutes a 'one man' 'very small organisation' - literally one man or...?
Out of interest, EGBKFLYER, how many people work in the organisations you've been working with and what split licensed/unlicensed?
I've had a few owners ringing me today concerned about the CAA letter regarding Subpart G/F etc and what it means to them.
I do find it strange that the CAA sends out letters to maintenance organisations and owners addressed to 'Dear Colleague'!
Out of interest, EGBKFLYER, how many people work in the organisations you've been working with and what split licensed/unlicensed?
I've had a few owners ringing me today concerned about the CAA letter regarding Subpart G/F etc and what it means to them.
I do find it strange that the CAA sends out letters to maintenance organisations and owners addressed to 'Dear Colleague'!
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Very interesting post, thank you.
I don't wish to appear flippant but surely that one is easy. Almost everybody who can record an MP3 file on their laptop can get a degree in Multimedia. If you can knock up a website you can get a Masters in Multimedia (Univ of Sussex, my 1970s stomping ground...)
Is it really worded that way?
And they wanted all three to be licenced engineers or graduates.
Is it really worded that way?
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This whole debacle is a Human Factors Issue!
Its got so many people wound up / perplexed / uncertain of position / lacking in current information that it is a HF analysists dream.
I'm not applying for CAMO status yet either - why should I when the rules are in place and might / might not change with less than a month to go? This is something the CAA just dont want to grasp! Extending the deadline to January 2009 wont change anything unless and until the rules are finalised and in place.
As for making 5-1-09 the new deadline instead of September 2009 so as to avoid commercial losses to those CAMOs who already made the leap, surely these people did so fully knowing changes to Part M are / may be in the offing? Now we all have to leap before the landing ground is ready,while other EU countries will probably have another year to deal with this - nice level playing field play on.
The real reason must be the CAA cant cope with the workload, and has no system to deal with it. A maintenance company must have sufficient staff for the work it does or it is not in compliance with the rules, gets told off and shut down. Should this not work the other way too?
When it is sorted then I might apply - the NPA made slightly better reading than the original Part M, but I might just get an FAA IA instead and re-register the plane N reg just to get away from this mess.
Its got so many people wound up / perplexed / uncertain of position / lacking in current information that it is a HF analysists dream.
I'm not applying for CAMO status yet either - why should I when the rules are in place and might / might not change with less than a month to go? This is something the CAA just dont want to grasp! Extending the deadline to January 2009 wont change anything unless and until the rules are finalised and in place.
As for making 5-1-09 the new deadline instead of September 2009 so as to avoid commercial losses to those CAMOs who already made the leap, surely these people did so fully knowing changes to Part M are / may be in the offing? Now we all have to leap before the landing ground is ready,while other EU countries will probably have another year to deal with this - nice level playing field play on.
The real reason must be the CAA cant cope with the workload, and has no system to deal with it. A maintenance company must have sufficient staff for the work it does or it is not in compliance with the rules, gets told off and shut down. Should this not work the other way too?
When it is sorted then I might apply - the NPA made slightly better reading than the original Part M, but I might just get an FAA IA instead and re-register the plane N reg just to get away from this mess.
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Got a nice letter from [email protected] today teling me the CAA line
I'm so p*ss*d off I've fired off a letter to my MP and to the Chair of the Transport Select committee as well as telling her what I think about the way the CAA (uniquely within the EU) has decided to act.
What is is to have an organisation that cares about you.........
I'm so p*ss*d off I've fired off a letter to my MP and to the Chair of the Transport Select committee as well as telling her what I think about the way the CAA (uniquely within the EU) has decided to act.
What is is to have an organisation that cares about you.........
Last edited by robin; 30th Aug 2008 at 08:19.
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Camlobe,
I also endorse the others and compliment you on a very perceptive post, which got to the heart of the matter.
Suffice to say that I have been making these noises to EASA and the CAA for some time in my capacity as a so called 'expert' on GA regulatory matters. I have had a - very polite - conversation very recently with one of the Belgrano senior people and he has written to me explaining the reasons for their decision re timing of implementation of the revised Part M (despite it still being stuck in the Commission / EU Parliament process). I hope to get his permission to make his reply more widely available, but time has not been on my side this week. In the meantime though I am told there will be a more extensive explanation on the CAA website very soon - like in the next week.
I agree with another forumite that for EASA / the EU political process to make a breach of the regulations by a person carrying out the tasks a criminal offence is absolutely outrageous. I see the natives rebelling soon....
Over the last few years I have been converted from a fairly conformist sort of individual to an absolute rebel and libertarian, by my experience of dealing with aviation rulemaking first hand. I never knew I could swear so much!
I also endorse the others and compliment you on a very perceptive post, which got to the heart of the matter.
Suffice to say that I have been making these noises to EASA and the CAA for some time in my capacity as a so called 'expert' on GA regulatory matters. I have had a - very polite - conversation very recently with one of the Belgrano senior people and he has written to me explaining the reasons for their decision re timing of implementation of the revised Part M (despite it still being stuck in the Commission / EU Parliament process). I hope to get his permission to make his reply more widely available, but time has not been on my side this week. In the meantime though I am told there will be a more extensive explanation on the CAA website very soon - like in the next week.
I agree with another forumite that for EASA / the EU political process to make a breach of the regulations by a person carrying out the tasks a criminal offence is absolutely outrageous. I see the natives rebelling soon....
Over the last few years I have been converted from a fairly conformist sort of individual to an absolute rebel and libertarian, by my experience of dealing with aviation rulemaking first hand. I never knew I could swear so much!
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AND, wasn't there supposed to be a COST JUSTIFICATION for making such changes within the EU before any rule making could take place? I know originally they (the commission) argued that because some countries had already started the process ie JAA that the need had been already established. It sickens me that as an aircraft owner I have no say in how my aircraft should be kept airworthy and yet I'm ultimately responsible for it. Do they (the CAA) believe by increasing the costs (30% year on year) to maintenance organisations and hence to their customers this promotes better airworthiness. Grrrrrr again!
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Part M for Mess-up
Hopefully my earlier post was considered informative and accurate in its content. There is the usual situation of individual interpretation by surveyors that will add further 'fun and games', as well as further potential movement of goalposts.
jxk, regarding your posts, I tried to ascertain what the costs would be for combined Part 145 and Sub Part G and I at renewal time next April. This was of particular interest to me as, like all other Part 145's, my approval renewal fee in April 2008 was somewhat higher than I was expecting. Foolishly, I expected an increase of inflation plus 6% (what we all have been told will be the standard CAA pricing updates to maintain their self-funding capability), giving around 10% max. Boy oh boy, did I get it wrong. The way I do maths, £2100 to £2786 is just under 30%.
I have been told by CAA Policy dept that the fees will be going up approximately 3% compared to the 2008 rates. And that the fee increases are decided 18 months in advance. Well, if they are decided 18 months in advance, the industry could be informed 18 months in advance, assisting in financial planning. He didn't tell me what the combined approval fee would be though. Also, I haven't been told how much extra the CAA will want in order to add another type or types to the Sub Part G approval. I am guessing that each and every addition will be classed as a 'variation' and they arn't cheap to obtain. Have a look at the CAA ORS series scheme of charges. So, more money to be found by the organisation and billed again to the customer.
Gives you a warm feeling to know EASA are only concerned with your safety, not their pension plan.
EGBKFLYER, my apologies for my omission.
smarthawke, I would be very interested to hear what your surveyor comes back with.
IO540, re the wording, I am at home at the moment and not near the EASA Part M Sub Part G, Sub Part I or Part 145. However, the content of the EASA documents do state such. I will try and locate the specific paragraphs when back in the office. As a quick breakdown, For the certifying engineer in the Part 145, he doesn't have to be an experienced engineer. The printed words are clear. A graduate with an 'appropriate' degree and a few months in an 'aviation enviornment' can gain and hold hold a Part 66 'C' licence allowing base maintenance certification. Tech records departments, battery servicing bays and seat maintenance bays are all classed as an 'aviation enviornment'. The reality is you could have a graduate with absolutely no live aircraft experience certifying aircraft as fit to fly following deep and heavy maintenance. Now doesn't that make you feel good next time you take your family away on an airliner?
The EASA M.A documents for Sub Part G and I do state the positions held will be either a licenced person or a graduate.
Malcolm, I totally agree, it is a serious Human Factors issue. Unfortunately, I don't see the situation improving for small organisations.
robin, please let us know what replies you get.
David Roberts, like yourself, I have tried to be a conformist. Like yourself, I am running out of patience, even to the point of considering dropping my Part 145, complete with its unjustifiable costs, and concentrating on 'N'reg.
camlobe
jxk, regarding your posts, I tried to ascertain what the costs would be for combined Part 145 and Sub Part G and I at renewal time next April. This was of particular interest to me as, like all other Part 145's, my approval renewal fee in April 2008 was somewhat higher than I was expecting. Foolishly, I expected an increase of inflation plus 6% (what we all have been told will be the standard CAA pricing updates to maintain their self-funding capability), giving around 10% max. Boy oh boy, did I get it wrong. The way I do maths, £2100 to £2786 is just under 30%.
I have been told by CAA Policy dept that the fees will be going up approximately 3% compared to the 2008 rates. And that the fee increases are decided 18 months in advance. Well, if they are decided 18 months in advance, the industry could be informed 18 months in advance, assisting in financial planning. He didn't tell me what the combined approval fee would be though. Also, I haven't been told how much extra the CAA will want in order to add another type or types to the Sub Part G approval. I am guessing that each and every addition will be classed as a 'variation' and they arn't cheap to obtain. Have a look at the CAA ORS series scheme of charges. So, more money to be found by the organisation and billed again to the customer.
Gives you a warm feeling to know EASA are only concerned with your safety, not their pension plan.
EGBKFLYER, my apologies for my omission.
smarthawke, I would be very interested to hear what your surveyor comes back with.
IO540, re the wording, I am at home at the moment and not near the EASA Part M Sub Part G, Sub Part I or Part 145. However, the content of the EASA documents do state such. I will try and locate the specific paragraphs when back in the office. As a quick breakdown, For the certifying engineer in the Part 145, he doesn't have to be an experienced engineer. The printed words are clear. A graduate with an 'appropriate' degree and a few months in an 'aviation enviornment' can gain and hold hold a Part 66 'C' licence allowing base maintenance certification. Tech records departments, battery servicing bays and seat maintenance bays are all classed as an 'aviation enviornment'. The reality is you could have a graduate with absolutely no live aircraft experience certifying aircraft as fit to fly following deep and heavy maintenance. Now doesn't that make you feel good next time you take your family away on an airliner?
The EASA M.A documents for Sub Part G and I do state the positions held will be either a licenced person or a graduate.
Malcolm, I totally agree, it is a serious Human Factors issue. Unfortunately, I don't see the situation improving for small organisations.
robin, please let us know what replies you get.
David Roberts, like yourself, I have tried to be a conformist. Like yourself, I am running out of patience, even to the point of considering dropping my Part 145, complete with its unjustifiable costs, and concentrating on 'N'reg.
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Does anyone from the CAA read these posts or care that there is such a jumble of complete confusion existing for aircraft owners and maintenance organisations???
Even the documents they do send out to me just seem like so much gobbledegook! I wonder if we could set the people from the TV programme WATCHDOG on to them? Taking you aircraft for maintenance should be no more difficult than getting your car MOT'd.
EU Regulation 2020/8130 Part 12 Chapter 7 Paragraph 1066 subparagraph xii or Grrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr.
Even the documents they do send out to me just seem like so much gobbledegook! I wonder if we could set the people from the TV programme WATCHDOG on to them? Taking you aircraft for maintenance should be no more difficult than getting your car MOT'd.
EU Regulation 2020/8130 Part 12 Chapter 7 Paragraph 1066 subparagraph xii or Grrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr.
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Smarthawke. The organisations I work with are split as follows:
Org 1: One Part 66/ BCAR engineer/ 2 full-time 'technicians' (i.e. not 66 or BCAR qualified). One accountable manager, one accountant and a quality manager (me!). This organisation is Subpart F and G approved, with I privileges.
Org 2: One part 66/ BCAR engineer who is also the accountable manager. 1 full-time technician, 2 admin staff and a quality manager (me again). This organisation is well into the process of getting F and G with I privileges.
Org 3: 2 Part 66/ BCAR engineers/ 2 (I think) technicians, accountant, accountable manager, quality manager. This organisation has just been Subpart F and G approved with I privileges.
As far as qualifications for ARS (Airworthiness Review Staff - you can tell the first language is not English with that acronym...): M.A.707(a):
Note point 2. IO540 - I think the degree in Knitting will not suffice!
Camlobe -
Not as far as I can see - there are several statements to the effect that the certifying staff must have understanding of what they are certifying before they do so (M.A. 607(a):
One of my tasks as Quality Manager is to ensure that certifying staff (who are formally approved by me as it says above underlined) understand what they will be signing off!
Org 1: One Part 66/ BCAR engineer/ 2 full-time 'technicians' (i.e. not 66 or BCAR qualified). One accountable manager, one accountant and a quality manager (me!). This organisation is Subpart F and G approved, with I privileges.
Org 2: One part 66/ BCAR engineer who is also the accountable manager. 1 full-time technician, 2 admin staff and a quality manager (me again). This organisation is well into the process of getting F and G with I privileges.
Org 3: 2 Part 66/ BCAR engineers/ 2 (I think) technicians, accountant, accountable manager, quality manager. This organisation has just been Subpart F and G approved with I privileges.
As far as qualifications for ARS (Airworthiness Review Staff - you can tell the first language is not English with that acronym...): M.A.707(a):
To be approved to carry out airworthiness reviews, an approved continuing airworthiness management organisation shall have appropriate airworthiness review staff to issue M.A. Subpart I airworthiness review certificates or recommendations.
In addition to M.A.706 requirements[general stuff], these staff shall have acquired:
1. at least five years experience in continuing airworthiness, and;
2. an appropriate Part-66 licence or an aeronautical degree or equivalent, and;
3. formal aeronautical maintenance training, and;
4. a position within the approved organisation with appropriate responsibilities.
In addition to M.A.706 requirements[general stuff], these staff shall have acquired:
1. at least five years experience in continuing airworthiness, and;
2. an appropriate Part-66 licence or an aeronautical degree or equivalent, and;
3. formal aeronautical maintenance training, and;
4. a position within the approved organisation with appropriate responsibilities.
Camlobe -
The reality is you could have a graduate with absolutely no live aircraft experience certifying aircraft as fit to fly following deep and heavy maintenance.
In addition to M.A.606(g), certifying staff can only exercise their privileges, if the organisation has ensured:
1. that certifying staff can demonstrate that in the preceding two-year period they have either had six months of relevant maintenance experience or, met the provision for the issue of the appropriate privileges; and,
2. that certifying staff have an adequate understanding of the relevant aircraft and/or aircraft component(s) to be maintained together with the associated organisation procedures...
1. that certifying staff can demonstrate that in the preceding two-year period they have either had six months of relevant maintenance experience or, met the provision for the issue of the appropriate privileges; and,
2. that certifying staff have an adequate understanding of the relevant aircraft and/or aircraft component(s) to be maintained together with the associated organisation procedures...
Last edited by EGBKFLYER; 31st Aug 2008 at 08:09.
The back to birth history requirement is an interesting one. Our Cessna was built in 1967 and has 10'000 hours. The log books go back to 1983 and the 7000 hour point.. Therefore 16 years and 7000 hours of it's life are missing. Anybody know what will happen when it comes up for ARC renewal? We have operated it without question for 14 years and 6 C of A renewals.
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Ericferret,
There is no specific back-to-birth history requirement, although I can see where some people may get that idea. The bit of Part M you're interested in is M.A. 710:
The person doing the Airworthiness Review will therefore examine all available records to determine the above. If there is a question over a particular part of the documentation (e.g. missing ADs in a missing logbook), inspections will be carried out as required and the CAA informed (MA710(h)). CAA will ultimately decide what, if anything, needs to be done to solve the problem.
I think in your case you'll have no problem.
There is no specific back-to-birth history requirement, although I can see where some people may get that idea. The bit of Part M you're interested in is M.A. 710:
M.A.710 Airworthiness review
(a) To satisfy the requirement for an M.A.902 airworthiness review of an aircraft, a full documented review of the aircraft records shall be carried out by the approved continuing airworthiness management organisation in order to be satisfied that:
1. airframe, engine and propeller flying hours and associated flight cycles have been properly recorded, and;
2. the flight manual is applicable to the aircraft configuration and reflects the latest revision status, and;
3. all the maintenance due on the aircraft according to the approved maintenance programme has been carried out, and;
4. all known defects have been corrected or, when applicable, carried forward in a controlled manner, and;
5. all applicable airworthiness directives have been applied and properly registered, and;
6. all modifications and repairs applied to the aircraft have been registered and are approved according to Part-21, and;
7. all service life limited components installed on the aircraft are properly identified, registered and have not exceeded their approved service life limit, and;
8. all maintenance has been released in accordance with this Part, and;
9. the current mass and balance statement reflects the configuration of the aircraft and is valid, and;
10. the aircraft complies with the latest revision of its type design approved by the Agency.
(c) Through the physical survey of the aircraft, the airworthiness review staff shall ensure that:
1. all required markings and placards are properly installed, and;
2. the aircraft complies with its approved flight manual, and;
3. the aircraft configuration complies with the approved documentation, and;
4. no evident defect can be found that has not been addressed according to M.A.404, and;
5. no inconsistencies can be found between the aircraft and the paragraph (a) documented review of records.
(a) To satisfy the requirement for an M.A.902 airworthiness review of an aircraft, a full documented review of the aircraft records shall be carried out by the approved continuing airworthiness management organisation in order to be satisfied that:
1. airframe, engine and propeller flying hours and associated flight cycles have been properly recorded, and;
2. the flight manual is applicable to the aircraft configuration and reflects the latest revision status, and;
3. all the maintenance due on the aircraft according to the approved maintenance programme has been carried out, and;
4. all known defects have been corrected or, when applicable, carried forward in a controlled manner, and;
5. all applicable airworthiness directives have been applied and properly registered, and;
6. all modifications and repairs applied to the aircraft have been registered and are approved according to Part-21, and;
7. all service life limited components installed on the aircraft are properly identified, registered and have not exceeded their approved service life limit, and;
8. all maintenance has been released in accordance with this Part, and;
9. the current mass and balance statement reflects the configuration of the aircraft and is valid, and;
10. the aircraft complies with the latest revision of its type design approved by the Agency.
(c) Through the physical survey of the aircraft, the airworthiness review staff shall ensure that:
1. all required markings and placards are properly installed, and;
2. the aircraft complies with its approved flight manual, and;
3. the aircraft configuration complies with the approved documentation, and;
4. no evident defect can be found that has not been addressed according to M.A.404, and;
5. no inconsistencies can be found between the aircraft and the paragraph (a) documented review of records.
I think in your case you'll have no problem.
Bugger,
I was hoping that it would be cast into the darkness that is the LAA, meaning I would never have to darken the CAA's door again.
For a while now I have been proposing that older light aircraft say over 15 should be allowed to transfer over to the LAA system. This would be a one way journey at the owners choice and the aircraft would never be eligible for a CofA at any time in the future. The owners of these aircraft would benefit from reduced costs although there would also be a drop in hull value. The airworthiness authorities would benefit as a large number of aircraft would move outside the normal regulatory process.
Many older light aircraft e.g Cessna 150 have a low hull value that would suffer little from such a transfer. If offered I would certainly take this option.
I was hoping that it would be cast into the darkness that is the LAA, meaning I would never have to darken the CAA's door again.
For a while now I have been proposing that older light aircraft say over 15 should be allowed to transfer over to the LAA system. This would be a one way journey at the owners choice and the aircraft would never be eligible for a CofA at any time in the future. The owners of these aircraft would benefit from reduced costs although there would also be a drop in hull value. The airworthiness authorities would benefit as a large number of aircraft would move outside the normal regulatory process.
Many older light aircraft e.g Cessna 150 have a low hull value that would suffer little from such a transfer. If offered I would certainly take this option.
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EGBKFLYER
Thanks for the staff info - something I can report to my surveyor if I need to. Not exactly 'one man bands' which he told me are the only people who can apply to wear all 3 hats (ARC, CAM and CRS) and only then if they are NOT Subpart F, ie signing on your license (like M3).
I've applied to go on the Subpart G and I CAA courses which the surveyor told me I had to do to meet the requirements (not that that is mentioned in Part M) despite having been recommending CofA renewals for 18 years....
Thanks for the staff info - something I can report to my surveyor if I need to. Not exactly 'one man bands' which he told me are the only people who can apply to wear all 3 hats (ARC, CAM and CRS) and only then if they are NOT Subpart F, ie signing on your license (like M3).
I've applied to go on the Subpart G and I CAA courses which the surveyor told me I had to do to meet the requirements (not that that is mentioned in Part M) despite having been recommending CofA renewals for 18 years....
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Part M (for Muddle)
I’m finding it difficult to understand why Continuing Airworthiness is proving so difficult for the European bureaucrats to understand. Remember, that in general we are talking about little aircraft not Boeing 747s or Airbus 380s.
Today light aircraft are subject to 50hr, 6 month and annual inspections; in some cases this is more than the manufacturer’s maintenance schedule and requirements (but that’s by the by).
The maintenance requirements are determined by analysing airframe, engine, and propeller times in relationship to ADs (Aircraft Directives), SBs (Service Bulletins) and LAMS or LAMP (Light Aircraft Maintenance Schedule/Program). This data is recorded in the appropriate log books with a licensed engineer finally signing to say the work has been carried satisfactorily. Now, please explain why we need to introduce all these extra job titles to do what is a relevantly simple task?
This is not rocket science, come on let’s have some pragmatism and commonsense.
I’m finding it difficult to understand why Continuing Airworthiness is proving so difficult for the European bureaucrats to understand. Remember, that in general we are talking about little aircraft not Boeing 747s or Airbus 380s.
Today light aircraft are subject to 50hr, 6 month and annual inspections; in some cases this is more than the manufacturer’s maintenance schedule and requirements (but that’s by the by).
The maintenance requirements are determined by analysing airframe, engine, and propeller times in relationship to ADs (Aircraft Directives), SBs (Service Bulletins) and LAMS or LAMP (Light Aircraft Maintenance Schedule/Program). This data is recorded in the appropriate log books with a licensed engineer finally signing to say the work has been carried satisfactorily. Now, please explain why we need to introduce all these extra job titles to do what is a relevantly simple task?
This is not rocket science, come on let’s have some pragmatism and commonsense.
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EASA Head in the sand stupidity
The idea of the EEC level playing field for aviation is on the face of it a good one but the administration of this is totally out of proportion to the task in question.
We now have aircraft that are much more basic in construction an all modern cars maintained by an administrative system that is designed for the maintenance of large airliners and overseen by a bunch of beauraucrats that can't or won't see that the system that they are setting up is so totally disproportionate that it will kill with red tape the industry that they are charged with overseeing.
It is quite typical of the bureaucrat that they can't see that they will administer them self's out of a job.
The CAA has by overbearing administration had a large part in destroying aircraft construction industry in the UK and now with the help of EASA they have the maintenance industry in the UK in the way they are introducing part M to the UK.
As to turning "missing" an AD into a criminal offence.......... you might as well build another prison for all the licenced engineers in the UK because with the way the AD system works all engineers will miss a minor AD once in a wile.
Still I could look on the bright side at least in prison I will get three meals a day.......... I won't get that if EASA simply drives me out of business!
We now have aircraft that are much more basic in construction an all modern cars maintained by an administrative system that is designed for the maintenance of large airliners and overseen by a bunch of beauraucrats that can't or won't see that the system that they are setting up is so totally disproportionate that it will kill with red tape the industry that they are charged with overseeing.
It is quite typical of the bureaucrat that they can't see that they will administer them self's out of a job.
The CAA has by overbearing administration had a large part in destroying aircraft construction industry in the UK and now with the help of EASA they have the maintenance industry in the UK in the way they are introducing part M to the UK.
As to turning "missing" an AD into a criminal offence.......... you might as well build another prison for all the licenced engineers in the UK because with the way the AD system works all engineers will miss a minor AD once in a wile.
Still I could look on the bright side at least in prison I will get three meals a day.......... I won't get that if EASA simply drives me out of business!