Saturday, November 14, 2009

Draft Maintenance Regulations

CASA's new draft maintenance regulations are available for comment until 18th December.
http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_93516

A few years ago I was in Canberra for a presentation by CASA near the start of this project. The intent was to base it on EASA with local improvements for “world's best pratice” etc. The principle was to have outcome based regulations rather than prescriptive regulations.

My little experience with EASA is that they are very bureacratic and only make general aviation more difficult. My quick look at CASA's draft regulations indicate that they have failed to make them outcome based – they are very prescriptive and will introduce more bureaucracy and expense to us.

A few examples.

I can currently do the second inspection of the control system on an aircraft (mine in particular) after maintenance. The new regulation would make it very difficult for me to do that.

We currently have a maintenance release with a requirement for a daily inspection to be certified. The draft requirement is for a technical log with the pre-flight inspection to be signed by the pilot.

Take a look here to see how NZ does it.
http://www.caa.govt.nz/Advisory_Circulars/ac91-6.pdf Reasonably sensible in my opinion – it is a daily system, not a lot different than what we currently do and provides for a variety of means to comply.

However, the CASA requirement is "pilot in command of an aircraft for a flight must ensure that the information about the flight is recorded in the flight technical log for the aircraft (unless CASA has approved another means of recording the information)." No longer a record at the end of the day's flying. Take a look at the NZ AC again to see what you can expect when CASA fills in the details with their AC. Remember, that will be required after each and every flight.

Read that rule above in conjunction with a new requirement for the pre-flight inspection, if required by the aircraft's flight manual. The Decathlon and Laser manuals, for example, are quite specific on the pre-flight check – not an issue as it includes the usual things that a pilot would do anyway. Do you think that CASA will expect that it be certified in the new technical log or not? I didn't see a requirement for a daily inspection anywhere in these draft regulations.
Consider how you operate your aircraft, say, at an aerobatic contest or practice weekend with several flights back to back.
More unnecessary paperwork and more time wasted.

The requirement for fitting a fabricated part – only if it has been made by the approved maintenance organisation doing work on the aeroplane. A simple part such as the special canopy bolt for the Pitts – the maintenance organisation had to contract the work to a specialised machining company but it seems that is no longer acceptable. The alternative is to buy the original factory part or a get that other company to get that bolt approved as a PMA'd part.

Replace a few screws on your aeroplane. Make sure that they are accompanied by evidence that they conform to the specification and are eligible to be fitted to the aircraft. Much more prescriuptive than the current reegulations I believe.

It seems that these draft regulations require more scrutiny by those people who will pay more as a result. i.e. everyone should take a look and respond to CASA. Why can't we do things the way they are done in the USA? I thought that was the original intent of regulatory reform twenty years ago. Last time I asked that of CASA in a meeting in Canberra I was told that the FAA would like to change their regulations in the same way. Guess what – the American aviation community wouldn't let them. The Australian way is to ignore drafts and simpy whinge when the new requirements are imposed on us - it is time that we changed our approach to CASA.

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