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PlaneTorque Australia Pty Ltd Professional Aeronautical Consulting & Auditing Services ABN 23 104 977 942

PlaneTorque November 2008

elcome to the ninth issue of PlaneTorque. For those readers with any military time overseas my recent visit to Vung Tau in South Vietnam might be of interest. Boy has that place changed from the days when the Yanks and our guys were there. This was my first visit to Vietnam, although I did get close in the mid sixties up in a corner of Thailand, about 5 minutes from Hanoi in a Phantom. A few weeks ago now an associate and I were up there auditing for some offshore oil companies. The operator, his facilities, aircraft and staff were very impressive. There are not many Australian operators that would compare. That’s me under an EC155B looking like I know what I am doing.

So are all SB’s Mandatory? A recent encounter (In Australia) raised for me an old thorny issue. Are all Service Bulletins mandatory? Well clearly they are not, as succinctly stated in our legislation (Refer CAR 1988 Regulation 2(c) - Interpretation). 2 Interpretation (1) In these Regulations, unless the contrary intention appears: maintenance instruction means an instruction that is issued by: (a) CASA or an authorised person in writing under regulation 38; or

(b) the manufacturer of an aircraft, aircraft component or aircraft material; or (c) the designer of a modification or repair of an aircraft or aircraft component; but does not include an instruction issued by a manufacturer or designer if it is clear from the terms of the instruction that the manufacturer or designer regards compliance with the instruction as optional.

Issue 09

Motors & Gearboxes, Flap Motors & Gearboxes to name but a few. So what does our legislation say? Let’s start with CAR 1988 Regulation (2) again. manufacturer’s maintenance schedule, in relation to an aircraft, means a schedule issued by the manufacturer of the aircraft that sets out what maintenance should be carried out on the aircraft and when it should be carried out. (2A) A reference in these Regulations to maintenance on an aircraft includes a reference to maintenance on aircraft components and aircraft materials.

However, the sometimes overused phrase “Duty of care” should be considered for optional SB’s. I highly recommend each maintenance organisation documents why they have decided not to carry out an optional SB on a particular aircraft. This process should form part of its normal “Document Control Procedures”. Keep in mind also that often an optional SB actually enhances an aircraft’s performance or re-sale value or both.

And what about Class B aircraft Components? Most GA “Class B” aircraft utilise CASA Schedule 5 for their preventative maintenance needs. Far too many simply ignore the OEM’s recommended inspection, lubrication and overhaul information. For example if you read most maintenance manuals for this class of aircraft your will see recommendations for such components as Landing Gear Page 1 of 2

(2B) A reference in these Regulations to an aircraft component, or aircraft material, included in an aircraft includes a reference to an aircraft component or aircraft material that is usually included in the aircraft but that has been temporarily removed from the aircraft for any purpose (including for the purpose of having maintenance carried out).

Now we need to bring this into context by reading CAR 1988 41 41 Maintenance schedule and maintenance instructions (1) The holder of the certificate of registration for a class B aircraft must ensure that all maintenance required to be carried out on the aircraft (including any aircraft components from time to time included in or fitted to the aircraft) by the aircraft’s maintenance schedule is carried out when required by that schedule. Penalty: 50 penalty units. (2) A person must not use a class B aircraft in an operation if there is not a maintenance schedule for the aircraft that includes provision for the


PlaneTorque Australia Pty Ltd Professional Aeronautical Consulting & Auditing Services ABN 23 104 977 942

PlaneTorque November 2008

maintenance of all aircraft components from time to time included in, or fitted to, the aircraft. Penalty: 50 penalty units. (3) An offence against subregulation (1) or (2) is an offence of strict liability.

Logically the management of this process starts with some deep and meaningful reading of the OEM approved data and if necessary documents like repair schemes, SB’s, optional role equipment or STC’s and then transpose the results into the “Log Book Statement” and then flow that on into correctly entering ALL recommended maintenance tasks into the appropriate log book sections or computer Maintenance Control software.

for. Plus a bit of carefully worded marketing on the need to better address what has after all been acceptable “Custom and Practice” for many, many years now.

“T” tailed aircraft Take a close look at the next photo. It’s of a B1900D Vert/Horz Stab interface frame. Can you see the nasty looking crack? It’s there on both sides of the aircraft and when one considers how well the Horz Stab is attached to the Vert Stab I personally find it amazing that such a crack was possible.

AWB 02-003 The Manufacturer’s Maintenance Schedule And Your Aircraft’s Maintenance Schedule is worth a read also. In particular that section that covers accidents and resulting court cases. In a nutshell it is simply not adequate enough to only utilise CASA Schedule 5 without carefully reviewing the OEM, STC or repair data first to ensure there are no required maintenance tasks (Overhaul, Inspection, Lubrication, Testing) therein that should be added to the Log Book Statement. What really set me going on this subject was I heard during my rounds that it’s CASA’s intention to progressively insist (How exactly is that achieved?) on compliance with these regulations on the older existing GA Class B fleet. Personally I would have thought it would make more sense to set a target date for all stake holders to aim

And here’s something else to ponder on these often quite high “T” tailed beasts. How easy is it to get up there safely, remove panels and inspect? And just for the record this is not a photo of any aircraft I have been near of late but I sure do make a point of getting this area looked at during a CoA.

Warning when changing ISP’s I know this has got nothing to do with aircraft. Well it has if you rely on the internet to do your thing. Like yours truly. Let’s see if I can cut a long story short. OK I decided to move from iinet back to Bigpond. Reason: Saves Page 2 of 2

Issue 09

me about $35/month. What none of the sales people tell you is that it can take three to four days upon becoming disconnected from one ISP to being reconnected by your new ISP. I swear I would not have changed had I know this. I would have just revised my plan. Do I sound a tad “P’d Off!”? I should because I am. Process took eleven days!

What The! Where-What-When?

Answers in next months issue. Last months was taken in late March 2008 @ Camden airport south of Sydney. It’s a LSA – Colyaer Freedom made in Spain. Nice looking bird, walks on water also.

Useful Links

Well I would if I could, but let me refer you back to my para on changing ISPs

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Contact Info: Tel.: 08 93774669 FAX: 08 93774521 Mob.: 040 0377 054 E-mail: alan.jupp@ptaaus.com.au www: www.ptaaus.com.au


Iss09-Nov08