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RAAus Fails CASA Audit Again


Robert

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Was required to send photographic evidence of MTOW and 'Unsafe Aircraft' placards on instrument panel.

 

Supplied on 07/12/12.

 

Nothing yet........

 

Should point out that in the past, when doing a new rego (the above is not) you were supplied with an 'Unsafe Aircraft' sticker and told to affix prominently.

 

No mention was made with regards to photographing said placard (or others required placards), and sending in to complete rego.033_scratching_head.gif.b541836ec2811b6655a8e435f4c1b53a.gif

 

The inspector merely needed to observe the owner sign the form, that said placards were in place......

 

 

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Was required to send photographic evidence of MTOW and 'Unsafe Aircraft' placards on instrument panel.Supplied on 07/12/12.

Nothing yet........

 

Should point out that in the past, when doing a new rego (the above is not) you were supplied with an 'Unsafe Aircraft' sticker and told to affix prominently.

 

No mention was made with regards to photographing said placard (or others required placards), and sending in to complete rego.033_scratching_head.gif.b541836ec2811b6655a8e435f4c1b53a.gif

 

The inspector merely needed to observe the owner sign the form, that said placards were in place......

Check the tech manual. If it doesn't say a photo is required, it isn't. But I think you will find the tech manual requires it (it depends on what you are registered as, as to which section, but I think they all require it). You need to check:

 

- the renewal requirement; and

 

- the original registration requirement.

 

If you didn't send a piccie when you first registered in 2002 (or whenever), and the tech manual says you should, they will probably want it now,

 

dodo

 

 

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CFI, tech manual was 2007. Maybe RA-Aus didn't ask for the right stuff. Maybe things weren't checked to the letter, but to the spirit in the past. Or maybe it was poor administration. But the tech manual sets out the requirements. Basically, no goal posts have moved.

 

But we are now being checked on stuff that is basically trivia. It is important that a pilot getting into a plane gets a clear MTOW, expecially where it might be ambiguous (544kg or 600kg). But it isn't important that anyone has a photo of that placard, in my opinion. And I believe the warning sticker is to protect CASA from litigation, as the sticker does nothing for the structure or design of the plane, and anyone flying an RA-Aus plane without knowing the RA standard shouldn't be in it. So this is petty, following rules to the letter.

 

But that is a function of CASA pulling the pin on RA. Why they did that, and how we got into this position, how we failed three follow-up audits etc. are questions I would like the answer to.

 

In short:

 

1 provide what is requested if it is a genuine requirement (see tech manual) regardless of how petty it is. OK, then you can fly.

 

2 get answers from the board. What is going on? Who knows? Why aren't we told what is going on?

 

dodo

 

PS one example is non-LSA 24 rego requirement for original rego7.4.1 Photographs, para 12

 

12.

 

Each aircraft applying for registration shall have registration markings

 

applied to the aircraft as per Operations Manual. Photographs showing

 

the registration numbers on the port wing, on the appropriate vertical

 

surfaces, as well as a cockpit photograph showing the warning and

 

weight limit labels as per Section 7.4.3 Annex C for CAO 95.55 para 1.5

 

aircraft, shall be submitted with the registration application.

 

 

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Stop asking your board for info and ask the staff in the office. Who do you think is working on fixing the problem. Out of 13 board members only two have offered and come into the office to help.

Not true Black. If you are going to make bold claims here you must get your facts right.

 

Many Board members have offered help. I know of at least four that have been to Canberra to help out where they can. I have personally offered to give up my time and volunteered to go down to Canberra and spend the Christmas break in the office if it will be of any help.

 

What must be remembered here is the cost benefit equation. The registration issue is a very technical matter, and you must have a technical background to be of any help in this matter. Also only the consultant can give approval for processing.

 

While on this matter I was informed last night that the renewal forms will start to be sent out again, and the consultant will be seeking CASA approval to spot check every xx renewals (acceptable to CASA). If this is approved it will speed up the process considerably.

 

John McK

 

 

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. . . The registration issue is a very technical matter, and you must have a technical background to be of any help in this matter.

John, thanks for continuing to be one of the few Board Members who can not only spell communicate but actually do communicate - both send and receive. Some seem to have their finger stuck on the transmit button.

 

A question though, How is this a "very technical matter"? Is n't it just a question of checking a file against a checklist? How many engineering degrees does it take to decide if there is a photo of numbers on file or not. Similarly for all other items that need to be on file as per the official checklist? Surely this is a bulk clerical exercise? If all the records were online, you could write a computer program to do the checking. In fact, if they were online no errors would have been accepted by the computer program (if written correctly). There could be separate checklists for each aircraft class, LSA, UL, 95.10 etc.

 

 

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A question though, How is this a "very technical matter"? Is n't it just a question of checking a file against a checklist? How many engineering degrees does it take to decide if there is a photo of numbers on file or not. Similarly for all other items that need to be on file as per the official checklist? Surely this is a bulk clerical exercise? If all the records were online, you could write a computer program to do the checking. In fact, if they were online no errors would have been accepted by the computer program (if written correctly). There could be separate checklists for each aircraft class, LSA, UL, 95.10 etc.

It is relatively complex. Some of the files are 25 years old. Some of the requirements have changed. Some of the files contain contradictory information.

 

For instance (not quite real examples,but close)

 

1 an aircraft imported from South Africa, with SA de-registration cert, reference to a type certificate in Czechoslovakia... umm, would that be the Czech Republic today or the Slovak Republic? What do we accept from that country? Can I read Czech enough to confirm it is real?

 

2 Or how about an amateur built 19 rego - MTOW question, cockpit placard is 544kg, rego form and subsequent documentation say 384kg, but the ADS says 348kg? ADS should be definitive,but this leaves a payload of 20kg fuel and total crew weight of 95kg. Does it fly with two midgets? Suspect transposition error.

 

3 Or a 95.10 trike, built in the early '80's by Airborne, purchased about 1985, registered in about 1988?Have a look at the 95.10 requirements.

 

4 How about an aircraft with the rego photos showing the wrong number (forgot a digit!) ? It flew around for years like that!

 

5 What is the stall speed of an aircraft that doesn't really stall? Minimum controllable speed or canard stall speed? Tech manual just says stall speed, and the main wing doesn't stall.

 

Basically, you have to fully read through every file, and have a competent knowledge of the requirements. The average RA pilot does not have this knowledge. Plenty do,but it would be a minority. And the work started after aircraft started being grounded, so you start with a backlog, phone numbers on file are 15 years old, some people you phone can't get to their aircraft until the weekend etc.

 

The real issue is how we got into this mess. The way it is being handled now isn't too bad, considering the situation. Not brilliant, but with everyone overloaded, constant phone calls, I find it hard to criticise the effort. Again, the real issue is how we got into this mess.

 

dodo

 

 

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Yes. Terrific post dodo, and thanks for going to the trouble to provide that explanation.

 

If the Board was to post something along those lines on the RAA website, they would go a long way to treating members correctly and getting disenchanted members on side. But they don't appear capable of seeing or doing that.

 

But can you also please advise whether new aircraft registrations are still on hold?

 

 

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I am not a reliable source (I just tried to provide more help than hindrance). My understanding, which might be incorrect, is that flying school aircraft and new registrations get addressed as soon as possible, but this doesn't slow up the others as they are a tiny minority. There isn't any explicit prioritisation because it isn't practical, and might be unfair. Transfers got sort of left on hold for a period, but I think transfers don't get treated as registrations (for the purposes of the audit), so go through OK. As far as I know, nothing is on hold (except possibly registrations where there are real problems, not documentation issues).

 

One of the reasons I can't provide definitive answers to a lot of things is that I was trying NOT to ask questions unless absolutely necessary, so I wasn't a drag on the process. Even so, I think the first couple of days I was a net neutral, possibly negative,then I got enough understanding to be positive, but never fully effective. My knowledge of the tech manual requirements,and the intricacies is limited, whiles the tech manager and a couple of others had very comprehensive knowledge.

 

And Captain, I agree on the information issue. I really think that is the biggest single problem, and I don't know why they are not more open. But as I said, I was in trying to help with an immediate issue. I wasn't there to advise or criticise, so I just worked.

 

dodo.

 

 

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REGISTRATION UPDATE

 

Hi Guys,

 

I have some more information.

 

Apparently the office stopped sending out renewals when our authority was removed. That means there is a large backlog, and a real risk for those who don't check their expiry date of flying illegally.

 

What is happening is all files with rego due in December and January are being individually audited. Those with errors (heaps of them) are going into a pile and the owners individually contacted by phone about the missing paperwork. When the missing paperwork is supplied, the renewal is signed off by RAA as complete and given to the Consultant for formal sign off for processing. (Please don't ask me why it is done this way, or what they do if no phone number on file. I don't run the office)

 

The major items missing from files are -

 

1. No photographic evidence of the MTOW sign. Yes I know that this requirement is not in the current Ops manual, but CASA require it and it will be in the new Ops manual. You could argue the case on this, but the girls won't process your file without it. It is a simple matter so just do it. You can look up the CASA website under 95-55. but the basic wording is - "WARNING - This aircraft is limited to a maximum take off weight of xxx Kg" You should all know your MTOW. The auditor will accept a DYMO label on the dash in plain view of the passenger. You need to take a photo of the sign, and on the back state that the sign is fixed to aircraft registration number xxx. Sign and date the photo. Currently the Auditor will also accept an electronic copy stating the same thing, and use the email address as proof of compliance. There may be an issue if the registered owner and the email address don't match. To avoid any potential issue, I would also include my membership number with my name. Also include your phone number.

 

2. No photographic evidence of the yellow and black warning sign. Here again take a photo, and on the back of the photo state it is from aircraft registration number xxx sign and date the photo.

 

3. No photo of the registration numbers under the wing. The requirement are the same as above.

 

4. No weight and balance information. I know some of the older aircraft in the 19 category did not require weight and balance at the time of registration. Here would be where you could argue the point.

 

5. Flying hours for the past year and the number of landings. Yes I know that you normally fill in these numbers at the time of renewal, but at the moment you are not getting your renewals.

 

OK what to do. Well you could wait to be contacted by the office about missing paperwork, or become PROACTIVE.

 

My advice is to everyone with rego due in the next few months is to do all the above, and send it into the office now, even if you believe it has already been done. Photos have been lost from the files, and I bet very few can comply with item number one. This way your file will be updated and placed in the completed audit file, ready for sign off by the consultant, and formal processing. If you also include a check or credit card details the process can be completed without you being contacted for payment.

 

The alternative is to wait for x days/weeks/months, until your name comes to the top of the pile for an individual phone call telling you what paperwork is missing. You then supply that missing paperwork and it then goes into your file for checking again. Isn't it better to just do it now, and for most people if they do all the 5 items above they will cover the most common missing items, and their file will progress straight to the processing stage.

 

John McK

 

 

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Hi John.

 

This sticker is on the back of the pilots seat in on my certified Drifter, in clear view of any passenger.

 

Is it what they are after for MTOW ?

 

19989-788e0fd22823cb4c710e118cb3ee65dd.jpg623974233_DSCI0002(Small).JPG.1f56314495a14f7b649785105e92a764.JPG

 

Kiwi.

 

Ps The sticker is 22 years old !

 

 

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REGISTRATION UPDATEHi Guys,

I have some more information.

 

Apparently the office stopped sending out renewals when our authority was removed. That means there is a large backlog, and a real risk for those who don't check their expiry date of flying illegally.

Thanks for the update John. It is truly appreciated.

Is it just me or does this seem quit bizarre to read Johns words after the update on the Ra-Aus Website???

 

Perhaps not outright disinformation but CERTAINLY NOT THE IMPRESSION THIS UPDATE PRESENTS IMO.

 

Aircraft Registration Update 14/12/12

December 14, 2012 | opsassist

 

The aircraft registration issue is being resolved, albeit slowly. The backlog of aircraft which have no identified issues on file has been dealt with thanks to a huge effort from the staff and the volunteer members who have been assisting for the past two weeks.

 

This leaves approximately 60 files that require as a minimum, a photo of the MTOW placard through to a Type Certificate from a foreign country. Where issues can be handled by phone and email we have both staff and volunteers contacting the members and advising them as to what is required so that the registration can proceed.

 

Paul Middleton

 

Secretary RA-Aus

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Hi John.This sticker is on the back of the pilots seat in on my certified Drifter, in clear view of any passenger.

 

Is it what they are after for MTOW ?

 

19989-788e0fd22823cb4c710e118cb3ee65dd.jpg[ATTACH=full]19989[/ATTACH]

 

Kiwi.

 

Ps The sticker is 22 years old !

That should do it Kiwi. Make sure you write on the back of the photo that the the sign is attached to your Drifter, rego number xxx, sign and date the back of the photo.

 

John McK

 

PS Twenty two years old!!! The sign sure does look its age. Ingle person operation, and Oading Limitations could be confusing to some. Perhaps a fresh sign would be appropriate.

 

Also, the note about nose ballast, although not specified, refers to DEAD ballast. Live sheep would not be acceptable.003_cheezy_grin.gif.c5a94fc2937f61b556d8146a1bc97ef8.gif

 

 

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That should do it Kiwi. Make sure you write on the back of the photo that the the sign is attached to your Drifter, rego number, sign and date the back of the photo.John McK

 

PS Twenty two years old!!! The sign sure does look its age. Ingle person operation, and Oading Limitations could be confusing to some. Perhaps a fresh sign would be appropriate.

 

Also, the note about nose ballast, although not specified, refers to DEAD ballast. Live sheep would not be acceptable.003_cheezy_grin.gif.c5a94fc2937f61b556d8146a1bc97ef8.gif

I don't sit in the back often. You would have read it more than I have.

 

air_brakes.jpg.fd53308682c4887da173d8a229a7f639.jpg

 

Kiwi.

 

ps. How's the Bushcaddie going?

 

 

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Thanks for the update John. It is truly appreciated.Is it just me or does this seem quit bizarre to read Johns words after the update on the Ra-Aus Website???

 

Perhaps not outright disinformation but CERTAINLY NOT THE IMPRESSION THIS UPDATE PRESENTS IMO.

I was just re-reading the RAAus web site thinking the same thing.

 

Kiwi.

 

 

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Can someone tell me who has either of these two signs available that we can add mtow figures to or can we fabricate them ourselves. Infomation for me and everyone else.Thanks

Mine is from a Certified Drifter, but here are the links for the others.

 

For 95-10

 

http://www.raa.asn.au/wp-content/uploads/2012/02/Section-7.1.4-Annex-C-Warning-Notice.pdf

 

For "19's" and MTOW for all other aircraft.

 

http://www.raa.asn.au/wp-content/uploads/2012/02/Section-7.4.3-Annex-C-Warning-Notices.pdf

 

Kiwi.

 

 

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A thumbnail dipped in tar will do.

 

Accurate and legible are important.

 

Just because your rego type allows 544kg or 600kg doesn't mean your aircraft can carry 544kg. The MTOW should be the registered MTOW, so use the factory figure, or if 19- or 95-10, the calculated MTOW. Some 95-10 may be only good for 280kg, not the 95-10limit of 300kg. Some 19- may have MTOW well under 600 or 544

 

dodo

 

 

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If anyone needs to know the wording for the placards, or needs a checklist of what is required or anything else, as far as I understand, it all comes from the RA technical manual.

 

If you have sent in the correct information for first registration at some time in the past, and the correct information for renewal now, that should be OK, unless there is some underlying problem (eg something like the type certificate is no good, or something else beyond your control).

 

So if you want a checklist, look at the RA technical manual for your aircraft's registration type. See section 7 http://www.raa.asn.au/safety/technical-manual/

 

The Annexes show the wording to be used for the placards , although the MTOW one is pretty obvious ("MTOW number kg")

 

On the MTOW placard issue,it is clearly required in section 7, but isn't spelt out in the checklist for amateur builders in section 3, which might be why that is so often a problem.

 

dodo

 

 

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good information John...its a pity our representatives (the Board) are largely silent on this issue, the Executive is 'mute'' and our organisation (RAA) is evidently 'deaf' to the concerns of members...

Why don't you just go and bash on the door of the caravan?

 

 

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