Alan gains Maintenance Reliability Certificate from Convergent Performance
Archive | Technical
Registrations cancelled by CASA (other than by request)
Flight Safety Australia – A Maintenance Control question
The following is what I sent in to CASA today.
This article was under the header of Flight Safety Advisors – Albert Fleming – FSA Sydney, so I will address my thoughts to him.
Dear Albert,
Nice piece of Swiss Cheese (James Reason would be proud of you).
Based on the story content only and taking it on face value we are clearly looking at several serious breaches of common sense by senior management, not to mention legislation. Lets just deal with the common sense matters here and leave the CAR’s CASR’s CAO etc etc to others to wax lyrical about.
- Why did CASA not insist that this company had a Deputy MC?
- Why did the CEO of company X not insist on a deputy MC?
- Why did the MC not insist he/she had a deputy?
- Lets assume the above three questions are not based on fact and there was a Deputy MC. Why was there not a documented (Perhaps there was, but if there was it clearly wasn’t used) and well understood procedure for the Deputy MC to take over responsibility whenever the normal MC was off-line (For whatever reason)?
- Why was this modern (Another assumption on my part) company not using CASA’s email alert system via its emergency IT system. An off site back-up computer who’s operator was alerted whenever the companies IT system went down. This emergency PC Operator was also trained in essential services support such as AD Alerts.
- Lets again assume that by “computer system was down” what is meant is a bigger problem. ie: Nationwide loss of IT capability for whatever reason. At approx 08:35 Hrs the new receptionist places the FAX in the MC’s IN TRAY, he/she should be trained to not simply place pieces of paper from CASA into “IN TRAYS”, he/she must be trained to verbally advise the owner of that “IN TRAY”. Can’t find the owner? Tell his/her deputy. Can’t find his/her deputy? Tell a technical person of some type (In this case the Maintenance Specialist). Can’t find anyone in the office? Call the Chief Pilot. Can’t contact Chief Pilot or his/her deputy? Call the CEO (By whatever title he/she uses).
- As an aside have you ever seen those “IN TRAYS” that look like the owner never clears them? You know, its about a foot high with documents of all types stacked therein. Now how can anyone be sure that when placing anything (In this case a mission critical FAX) into such a beast it will stay on top for long? What the MC (And his/her deputy) must have are dedicated URGENT IN TRAY’s (That must not be allowed to grow contents wise) or they might even have a dedicated CASA Comms/AD IN TRAY.
- OK so the receptionist simply does as explained – places FAX in MC IN TRAY. The maintenance specialist only becomes aware at 13:00 Hrs. Lets also assume that the compliance time clock started ticking as described at 08:30 Hrs (Time AD received). Further that we are talking about ten hours of normal time not ten flight hours (This only becomes clear later when we are told how the IT guy enters the AD into the computer). Based on these assumptions at 13:00 Hrs the clock hours to run would be at 5.5 hours. Maintenance specialist gets the AD inputted into computer by IT guy, who stuffs it up. Two very important steps appear to be missing here:
i) The maintenance specialist should have observed the data entry process carefully to ensure our IT guy did it correctly.
ii) As soon as the maintenance specialist became aware of the AD he should have telephone all affected outstations to ensure they were aware of the very short compliance time line and he/she should have faxed a copy of the AD to each outstation.
h) Event is logged into the companies SMS dB and the following recommendations are entered and acted upon:
i) CASA are advised of the breach by the MC and the corrective actions being undertaken.
ii) A deputy MC position is established (If not already in place)
iii) All involved are trained/retrained on the required procedures. This includes AD processing and computer data entry.
iv) Emergency plans reviewed to ensure loss of IT capability is adequately covered
v) Quality Systems Manager to carry out several random audits of the process over the coming months to ensure the system operates as required.
vi) The audit findings are also logged in the SMS dB.
Anyone interested in a very good SMS dB should contact me. I am currently (This may change with time) offering a FREE dB tool to clients. There will of course be some costs involved in installation and training of key staff. In the short term I would be more than happy to send you a demo CD.
Unregistered Australian Aircraft
Dear fellow LAME’s,
A few days ago I was made aware of what appears to me to be a potentially serious situation.
As you would all be aware Australian aircraft must be registered under new rules. The following is a cut and paste from CASA web site.
Registrations cancelled by CASA (other than by request)
The registrations of the aircraft shown in the list below have been cancelled by CASA since 1 May 2006.Note that the aircraft’s certificate of airworthiness is no longer valid and the aircraft must not be flown. Flying an unregistered aircraft is an act punishable by law with up 2 years of imprisonment. It will be necessary to apply for a new registration should you intend to return the aircraft to the register at a later date.
Please note: Aircraft included in this list may have subsequently been re-registered under CASR Part 47.If you require any further information regarding an aircraft in the list you should contact the Aircraft Data Section of the Australian Civil Aircraft Register:
Please note: Aircraft included in this list may have subsequently been re-registered under CASR Part 47.If you require any further information regarding an aircraft in the list you should contact the Aircraft Data Section of the Australian Civil Aircraft Register:
Now what concerns me is “How many LAME’s out there actually check that the aircraft they are asked to perform maintenance on is still legally registered?”.
I have carried out a few 100 hourly’s (Call them what you will) in my time, but I can never, other than during an initial CoA inspection, recall viewing the CoR or CoA.
Just remember this, if its not registered then its CoA is not valid, it must be reissued. Indeed even if it is registered after the drop dead date of 1st May 2006 its CoA is still invalid. And of course a non-valid CoA will negate the issued Maitenance Release and any insurance cover.
Now take a look at the VERY LONG list of deregistered aircraft on CASA web site on the same page as above. Do you recognise any REGOs there. There are over 400 and they are not all amateur built types either. Sure there are a few (Very few) that are due to being BER.
You might like to pass this message onto to your mates in the industry. If it stops just one of them issuing a fresh MR when they shouldn’t its been worth it.