Mriya

Yes I was about to mention SIDS also. This is now a expected part of the maintenance schedule that needs to be carried out.

Hello from just across the way at Coldstream. I am the chief engineer at AvServe based there. I have CASA LAME + L2/L4 approvals and a good contacts for all avionics/radio issues too. There are a friendly bunch of people here plus a wonderful valley to fly around. I enjoy taking the YVFT Tecnam out from time to time. Regards, Justin

I'll claim the million dollars and answer that question. Darren is simply highlighting that if you have done maintenance to your aircraft that requires an independant inspection, but that inspection has not been carried out your aircraft can't be considered airworthy until such time as you arrange for these required inspections to be done and documented. If you have been doing maintenance per the Technical Manual (including independant inspection requirements) then you have already complied with his Airworthiness Notice and don't need to take any further action at this time. Fly safe, Justin

I will answer on the basis that this is a genuine query: The short answer is that all maintenance on RAAUS aircraft must be done per the RAAUS Techincal Manual. Therefore a current L1 can perform maintenance on their own aircraft, HOWEVER in accordance with the Tech Manual any disturbance of flight control systems requires an independant inspection to confirm correct assembly/rigging/safety of the system. This requirement extends right across the aircraft maintenance industry regardless of whether it is a B747 or a single seat privately owned ultralight. I would suggest that ANYONE who is considering exercising ANY RAAUS maintenance privileges that they may have should have a careful read of the RAAUS Technical Manual, because this is the document that defines how the work should be done. On a really bad day when you need to answer a Coroner's questions about maintenance you did on a crashed aircraft, this is going to be one of the primary documents that will either send you to jail or allow you to walk free based on whether you followed it's rules. It therefore pays to have a good understanding of this document and allow it to guide your maintenance practices. By the way, I don't claim to know it all either, and as a result of some of the discussions on this thread I now have a better understanding of how the CASR's and the RAAus Tech Manual fit together too. Regards Justin

Glad to see the conversation moving forward a little since I last commented. Lots of challenges for people and as always rules can make life more complicated for some people in unique circumstances. I would hope that in cases of genuine hardship level heads and calm conversations with those who can make a difference would result in acceptable outcomes to allow for continued innovation. It really sucks when red tape stifles creativity, so I really hope good pathways can be created to support the innovators. I also see someone wondering about reversed trim tabs: I obviously didn't give the whole story but was just focusing on the maintenance error. As I mentioned a whole series of factors combined and managed to breach every layer of defence (Textbook case of the James Reason Swiss cheese human factors model). In short the following factors combined, resulting in an aircraft taking off with reversed trim system: Errors in manufacturers maintenance data. Error in initial check following assembly per data. Error in independant check following assembly. Changes in key roles and certification responsibilities in maintenance organisation during aircraft maintenance visit. Error missed by pilot during daily inspection. The 4 LAME's involved had between 8 and 26 years of individual experience each and the two pilots involved were both CPL with +30 years full time flying experience each. I was the 26 year experience LAME. I tell the story because I reject the notion that experienced people don't make mistakes. Fortunately 'by God's grace' the bulk of errors are found before we are left with a smoking pile of bits, however we must never allow complacency or pride to creep in and erode the primary defences that have been established to protect us. I would hope that solutions can be found were unique challenges lie, but I suspect that for some people the resistance to conducting independant inspections is not due to an inability to comply, but rather an attitude of I have never done it before so why start now. Fly safe, Justin

I think Kaz (as a lawyer) explained that your interpretation of 'should' would be unlikely to stand up in court. I appreciate your frustration and dilemma. Maybe the real question you are asking is whether there are any allowances possible for the circumstances you describe. I honestly don't know the answer, but the question probably needs to be asked. Some aircraft are designed with systems that allow transport disassembly without the need to interfere with flight control systems. If no concessions are available in the regs I guess the only legal option for sole pilots in isolated areas is to select an aircraft that can be derigged for transport without the need to disturb flight controls. I hope my posts haven't sounded too harsh. Expression and intent are hard to gauge and communicate effectively. My hope in participating is that people (including myself) come to a better understanding of the regulations that govern us. I am not saying I always like or agree with them, but ultimately my feelings make no difference. I (and all of us) am/are obliged to observe them regardless of whether we agree with them. If a rule is genuinely unworkable then it should be brought to the attention of the appropriate authority as it is their job to ensure the regulations and rules work. Regards, Justin

My hope is that we have all been able to better appreciate the independant inspection requirements as they stand. I think it is fair to say that based on various comments there are plenty of 'knowledge gaps' that exist amongst our community. Debate that causes us to all go back and read the regulations is a good thing. I know I've now got a better understanding of how the various CAR's interact with the RAAus Technical Manual. I hope that for everyone who has participated, that they too can now claim to better understand the regulations and how to apply them in their circumstances. Fly safe (and legal) everyone.

Sorry AVOCET but you seem to be missing the fact that there have been NO RULE CHANGES. The AN simply highlights the rules that have always existed. The AN was issued at least in part because two well regarded and competant people would likely be alive if the existing rules had been followed. So it doesn't sound like a 'knee jerk reaction' to me. To answer your question 'Is this the future?' My response is 'I certainly hope so, in order to prevent similar tragedies from occuring in the future' Regards, Justin

Thanks John, I had just done some more reading and came to the same conclusion. Therefore it is the Technical Manual that defines our responsibilities on this matter. Seeing as the Technical Manual define the same basic requirement for independant inspections it doesn't make any real difference anyway.

I am happy to be corrected on this point if I am wrong however I see no exemption from CAR 42G for RAAus which means independant inspection regulations have always applied to RAAus. In this case any argument over our TM wording is irrelevant as 42G sets out requirements clearly. http://www.austlii.edu.au/au/legis/cth/consol_reg/car1988263/s42g.html

I seem to have been misquoted: I was in no way advocating ignoring safety issues. Tweaking a flight control to correct a minor trim issue (observing Service Manual limits of course) is elective maintenance that can be performed when the right tools and people are available. Similarly, at scheduled maintenance a number of flight control issues (ie: control cable / hinge replacements) can be anticipated and planned for. However unscheduled repairs will create logistical challenges that must be dealt with legally and appropriately. This is no different for any other sector of aviation.

I'm not sure how I can make it clearer, but let's have one more go: 1. INDEPENDANT INSPECTION REGULATIONS ARE NOT NEW! They were established at the dawn of aviation based on the VERY REAL RISK of maintenance errors compromising the safety of an aircraft, occupants, and people who happen to be on the ground under it. 2. The rules have NOT BEEN MADE ASSUMING ACCESS TO A L2. As a specific concession to this issue CASA pilots have always been authorised to perform independant inspections. For GA this means the LAME who must attend + a pilot can effect certification. The GA equivalent to the RAAUS problem that arises is how would a LAME who owns their aircraft at a remote location certify for flight control maintenance? Well guess what. They are legally required to get another LAME or pilot to do the independent inspection. The issue arises in RAAUS far more because we have been given a HUGE CONCESSION in being able to maintain our own aircraft, with very minimal training. RAAus enjoys a level of freedom concerning maintenance that simply don't exist in other sectors of aviation. However we are not at liberty to ignore aviation regulations, even if we don't like them. How do you think CASA will respond if they audit RAAus and see an organisation full of people who choose to 'flout' the rules that apply to them?

I second that reply. Unfortunately the law rarely allows for pragmatism in these matters. As a maintenance org this issue is unlikely to be a problem as we can invariably find an appropriate person to conduct a proper independant inspection. However this is more problematic for an owner who is a long way from other pilots or maintainers. Best suggestion to remain legal would be plan to do such maintenance when or where someone is available. Yes this may be a pain, but sometimes the law is like that.

I should add as a chief engineer in a CASA maintenance org I have had to conduct an investigation (and report to CASA) a maintenance error where a Cessna elevator trim system was installed in reverse sense and managed to escape detection despite the involvement of 4 LAME's. The error was only discovered after takeoff on a test flight. It was a classic case of multiple factors (including incorrect maintenance data) and highlighted the various Human Factors which lead to maintenance errors. So why do i tell this story? Simply because the evidence of history teaches us that errors will occur in maintenance. In fact it is estimated that on average 1 in 10 defects or errors will be missed (even by experienced people). Personally I was shocked by this figure as I would like to think that my personal performance is better than that, however in my experience I am now inclined to believe this statistic. Using this scary statistic you can deduce that with one person only working on a flight control system will result in 1 in 10 defects or errors going unnoticed. By complying with the independant inspection requirements this failure to detect rate will statistically drop to 1 in 100 defects. The airlines learnt the importance of mitigating these risks some time back. In my Qantas days we were told to avoid as an individual to even doing simple engine tasks on multiple engines during maintenance visits. Put simply the independent inspection process is designed to save lives. I don't know specifics, however it is possible there would be at least two more people would be alive today if a particular flight control defect had been identified during assembly or maintenance. Not only is it illegal to skip this regulatory requirement, but it also stack the odds against you of encountering a flight control defect or failure sooner or later, no matter how good you may think you are as a maintainer.

Let's not get too carried away. I just went back and read the Airworthiness Notice but didn't see anything sinister. Maybe some wording could be 'tidied up' a bit, but then most of us have probably written and sent something only to later re-read it and see better ways of wording it. Bottom line of how I believe it should be interpreted is that two independent (and qualified) people need to inspect and certify for flight control maintenance work when the controls have been disturbed. It is acceptable for one of these people to have been the one doing the work. The important thing is that both people certifying act independently of each other during their inspection/certification. The other aspect is with regards to reporting requirements. I interpret this as the requirement to report control system design defects or failures that are found during inspection (which have always been subject to reporting requirements) and are not a demand to 'dob in a mate' in the event of errors found within the course of applying this maintenance procedure. The time when a maintenance report would be in order is when the normal independant inspection procedure fails to detect an issue and the aircraft is released from maintenance with faults that are then detected at a later time. Finally, although Darren is not able to link this notice to recent events for legal reasons, I'd have thought 2 people dying in a recent accident that appears to have been caused by a control system failure that an independent inspection process is designed to detect is ample reason to highlight a longstanding requirement that has existed since the very early days of aviation regulations. So in summary, no conspiracies here. Just a simple reminder of regulations and requirements that we have always been required to observe.

It would seem that a number of people commenting here are not familiar with very long standing aviation regulations that mandate independent inspections whenever flight control systems are disturbed in maintenance. The requirement has also been in our Technical Manual and there is nothing new about it. It is nothing to do with adding costs and everything to do with keeping people alive. We are all human and make mistakes. History tells us that maintenance errors on flight control systems can easily end in a fatality, thus the need for double checks regardless of how good you may think you are. The regs allow for pilot to do the independent check. The simple fact is that if you ignore the legal requirement to do these safety checks you are removing a layer of safety which is intended to keep you alive by obliging a second inspection of a system which is critical to safe flight. The aircraft maintenance industry has long recognised the need for this check and none of us LAME's see it as an insult to our intelligence. In fact every so often it does the very thing it was designed to do when a 'fresh set of eyes' detects a problem that the main person doing the job has overlooked. As for keeping on top of your maintenance records, well guess what! As owner and maintenance controller it is required and expected of you to to properly record all maintenance work and ensure the correct maintenance schedule is observed. This has always been the case. If we expect to be able to continue to do our own maintenance and enjoy the autonomy that comes with RAAus we need to demonstrate an ability to comply with the rules that have always existed. There is no point in whinging about 'Big Brother' CASA interfering when so many of these fundamentals are being missed, misunderstood or worse still ignored. In short I see no excuse for people ignoring such a fundamental safety procedure (and legal obligation).

As a LAME I second the 'Right tighty' comment. These type of simple reminders are in common use in our industry, including this one. This one is used to assist in determining the direction a lock wire should be applied, especially when the bolt to be secured is mounted upside down or around a corner. It is in no way trying to be condescending or treat people like children, but rather recognise the human factors involved and the very real possibility of a mistake being made in these circumstances. Anything that helps reduce these common errors is good and should be embraced. Well done Darren (and RAAus) on getting this info out so quickly following such a sad accident.

Although we all know that electronics are highly unlikely to cause problems, it is worth noting that most airlines do require all electronic devices to be 'TURNED OFF' for TO and LDG. Once safely away from these critical phases of flight they then permit operations as long as the transmitting device is in 'FLT MODE'. The bottom line is that you will ALMOST CERTAINLY be breaking the airlines rules if you use your electronic device to record a take-off or landing. I only mention this in the interests of people being fully informed. What you choose to do with this info is up to you, but at least you will be able to make an informed decision.

Should also add, CASA released a bulletin on the subject of fire extinguisher maintenance last week. It sets out how the legislation currently sits. http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_90524

BCF can be purchased through Aviall. They require an aircraft rego in order to sell it. LAME is required to have appropriate accreditation to 'handle' or install extinguisher. The ozone regs are such that you are in criminal breach if you maintain a system containing ozone depleting substances without the appropriate training and competency assessments done. Please don't hear me saying I am supportive of all this red tape. I recently got one for a C172, so am familiar with the procedure.

Got my letter in the mail yesterday, however I tend to agree with the direction. From comments above it seems that people may not be aware that CASA apply a much higher 'recency' requirement on LAME's than 4 checks in 2 years. We need to demonstrate 6 months full time equivalent in two years in order to be eligible to keep signing out work so the new RAAus standard is a significant concession in comparison. The new system will also help protect against people who think an unlimited L2 (which in the past has been handed out with relative ease) means that you can do anything regardless of your actual experience on particular systems. As a LAME I was able to get an unlimited L2/L4 a number of years ago, however I have rightly 'self regulated' the jobs that I accept based on my experience. This means I have not accepted work/inspections of unfamiliar systems/structures such as wood construction as my experience does not cover this type of material. The proposed changes will simply protect us all against L2's who may currently be making unwise choices and working beyond their experience levels and therefore risking the lives of people. On that basis, I support the change.

Exadios is on the money. FR24 is a private network of ADS-B recievers that are linked by the net to the FR24 server. Their coverage is dependant on enthusiasts being willing to set up receivers and leave them on, providing a web feed. Gaps in FR24 coverage occur when no private receivers are active in a given geographical area. The coverage map listed earlier relates to the official Airservices Australia network which has been designed to give complete coverage for ATC purposes, however FR24 doesn't access this data.

Fltradar24 is real time in Oz, but has a 5min delay in the USA (signified by the different color aircraft on the display). As rightly pointed out it receives its aircraft position data via a private network of ADS-B receivers which pick up the broadcast GPS location that is sent out by all ADS-B equipped aircraft. Most, if not all large airliners are now ADS-B equipped, however at this time only a small number of GA / Charter aircraft are set up with ADS-B at this time. I was recently involved in the import of a C182 which had ADS-B equipment. ADS- B overcomes some of the limitations of conventional surveillance radar in that if two aircraft operating in Mode A or C are in close proximity to each other the return signal from the transponders in each aircraft occur simultaneously, effectively scrambling the return data. Airservices Australia would love to have every aircraft ADS-B complient, allowing them to shut down the radar network. You may remember they had a push for this outcome when faced with having to upgrade their radars a few years back. Probably good that they didn't succeed in that bid as the ongoing cost of having every aircraft ADS-B compliant would be borne by us all, even though at the time they were proposing subsidies for equipment fitment in all aircraft.

Talk about not following the aircraft/engine maintenance schedule, I suspect, is part of the reason RAAus sees the need to tighten up maintainer privileges. If you operate your aircraft beyond the approved maintenance schedule in respect to calendar time or TTIS, it can no longer be considered airworthy. My observations are that some owners have little appreciation of the responsibility and obligations they have as the maintenance controller of their aircraft. This statement is true of both some RAAus and VH owners, except at least with VH (unless they are an owner/builder) the maintenance must be certified by a LAME, who can then provide informed advice to the owner on a regular basis. RAAus are between a rock and a hard place when it comes to ongoing management of maintainer privileges. On one hand the growing membership want to maintain existing privileges, while on the other hand they are aware of the exposure to potential litigation from the widow of a pilot or pax who has died as the result of maintenance being carried out (or not being carried out) by a person who does nor possess the knowledge or skill to conduct this work in a competent manner and yet is approved by RAAus to do such work. RAAus is no longer comprised primarily of a bunch of enthusiasts who have built and maintained their 'minimum' machines, knowing every aspect of the build intimately. These days a significant percentage of members may come from a non-technical background, and have purchased a high performance machine, with little understanding or skill in maintaining it. Unfortunately, due to a lack of checks and audits, a culture has developed within RAAus where people believe they are entitled to do whatever they see fit with regards to maintenance, paying little or no attention to the approved schedule. Modifications are also done without consideration to the effect they may have on the CofA status. Is it any wonder that RAAus (and CASA) see the need to tighten up maintainer approvals for our aircraft?

As I understand it Windsor and Frank are both sort of right. The ERSA statement is how you tell if an ASIC is needed, however the assessment hinges around RPT ops. Of course, RPT operators come and go from some airports creating anomilies, because once an airport is listed it tends to stay that way regardless of whether continuing RPT ops occur. Personally I believe the ASIC system should only apply to International Gateways, or at worst extended to airports with regular RPT jet ops, however it is hard to remove the red tape once it is in place. I will go to the website and have my say though.